FEDERAL RAILROAD ADMINISTRATION 

OFFICE OF RAILROAD SAFETY 

MOTIVE POWER AND EQUIPMENT 

COMPLIANCE MANUAL

July 2012 
i 

MOTIVE POWER AND EQUIPMENT

Compliance Manual

TABLE OF CONTENTS

Chapter 1 - General Information 

Introduction .................................................................................................................. 1 - 1 

Program Goals ............................................................................................................. 1 - 2 

Basis for Regulation and Inspection ............................................................................ 1 - 2 

 Definitions and Roles 

Specialist .......................................................................................................... 1 - 3 

Motive Power & Equipment Inspector ............................................................ 1 - 3 

 State Equipment Inspector ................................................................................. 1 - 3 

 Customers .......................................................................................................... 1 - 3 

Credentials ................................................................................................................... 1 - 3 

Personal Safety............................................................................................................. 1 - 3 

Recommended Safe Work Procedures ........................................................................... 1 - 4 

Technical Bulletins ........................................................................................................ 1 - 4 

Contacts with News Media .......................................................................................... 1 - 4 

 Cooperation of FRA Personnel with Industry, Labor, & Other Agencies ..................... 1 - 5 

Subpoenas .................................................................................................................... 1 - 5 

Operating Equipment ................................................................................................... 1 - 5 

Delaying Trains .............................................................................................................. 1 - 5 

Unusual Occurrences .................................................................................................... 1 - 5 

National Transportation Safety Board.... .................................................................. . 1 - 6 

Chapter 2 - Inspection and Compliance Program

Introduction .................................................................................................................. 2 - 1 

Allocation of Resources ............................................................................................... 2 - 1 

 Regular Inspection Point ................................................................................................ 2 - 1 

Inspection / Activities Priorities.................................................................................... 2 - 1 

Accident Investigations ................................................................................................ 2 - 2 

 Congressional Complaints Inspections .......................................................................... 2 - 2 

Waiver Petition Investigations ....................................................................................... 2 - 2 

One-Time Movement Inspections .................................................................................. 2 - 5 

Regular Complaint Investigations ................................................................................ 2 - 8 

 Focused Enforcement Inspections ............................................................................... 2 - 9 

Sample Car/Locomotive Inspections ......................................................................... 2 - 10 

 MP&E Safety Concern & Recommendation Report F6180.4A ................................ 2 - 14 

Site-Specific (Routine) Inspections ............................................................................. 2 - 15 

Operation Life Saver Presentation .............................................................................. 2 - 17 

FRA's Jurisdiction Over Tourist And Excursion Railroads ........................................ 2 - 17 

Source Codes .............................................................................................................. 2 - 20 
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 Activity Codes............................................................................................................................................... 2 - 23 

Chapter 3- Enforcement Actions

General .......................................................................................................................... 3 - 1 

Determining When and What Enforcement Action Is Necessary ................................ 3 - 1 

 

Chapter 4 - Railroad Freight Car Safety Standards - Part 215

Introduction ................................................................................................................... 4 - 1 

Determining Noncompliance ........................................................................................ 4 - 2 

Freight Car Safety Standards Inspection Procedures .................................................... 4 - 3 

PART 215 - Railroad Freight Car Safety Standards ..................................................... 4 - 3 

Subpart A---General

§215.3 Application ............................................................................. 4 - 3 

§215.5 Definitions.............................................................................. 4 - 4 

§215.9 Movement of defective cars for repair ................................... 4 - 6 

§215.11 Designated inspectors ............................................................ 4 - 8 

§215.13 Pre-Departure inspection. ..................................................... 4 - 8 

Subpart B --- Freight Car Components 

Suspension System 

§215.103 Defective wheel ................................................................. 4 - 10 

§215.105 Defective axle and journal ................................................ 4 - 15 

§215.107 Defective plain bearing box: General .............................. 4 - 16 

§215.109 Defective plain bearing box: Journal lubricating system .. 4 - 16 

§215.111 Defective Plain Bearing .................................................... 4 - 17 

§215.113 Defective Plain Bearing Wedge ........................................ 4 - 17 

§215.115 Defective Roller Bearing .................................................. 4 - 17 

§215.117 Defective Roller Bearing Adapter .................................... 4 - 20 

§215.119 Defective Freight Car Truck ............................................. 4 - 21 

 Car Bodies 

§215.121 Defective Car Body........................................................... 4 - 26 

Draft System

§215.123 Defective Couplers ............................................................ 4 - 28 

§215.125 Defective Uncoupling Device ........................................... 4 - 31 

§215.127 Defective Draft Arrangement ........................................... 4 - 31 

§215.129 Defective cushioning device ............................................. 4 - 33 

Subpart C---Restricted Equipment 

§215.203 Restricted cars ................................................................... 4 - 33 

Subpart D---Stenciling

§215.301 General .............................................................................. 4 - 34 

§215.303 Stenciling of restricted cars ............................................... 4 - 34 

§215.305 Stenciling of maintenance-of-way equipment .................. 4 - 35 

Appendix D to Part 215 – Pre-Departure Inspection Procedure ..................... 4 – 36 
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Chapter 5 - Blue Signal Protection of Workmen - Part 218

Introduction ................................................................................................................... 5 - 1 

§218.1 Purpose. ................................................................................. 5 - 2 

§218.3 Application. ........................................................................... 5 - 2 

§218.5 Definitions............................................................................. 5 - 3 

§218.21 Scope ..................................................................................... 5 - 8 

§218.22 Utility Employee .................................................................. 5 - 10 

§218.23 Blue signal display ............................................................... 5 - 12 

§218.24 One-person Crew ................................................................. 5 - 14 

§218.25 Workers on a main track ...................................................... 5 - 14 

§218.27 Workmen on track other than main track ........................... 5 - 15 

§218.29 Alternate methods of protection.......................................... 5 - 18 

§218.30 Remotely controlled switches) ............................................. 5 - 21

Chapter 6 - Rear End Marking Device--Passenger, Commuter and Freight Trains - 

Part 221

 

Introduction ................................................................................................................... 6 - 1 

§221.3 Application ......................................................................................... 6 - 1 

§221.5 Definitions.......................................................................................... 6 - 2 

§221.13 Marking device display ...................................................................... 6 - 2 

§221.15 Marking device inspection ................................................................. 6 - 3 

§221.16 Inspection procedure .......................................................................... 6 - 4 

§221.17 Movement of defective equipment .................................................... 6 - 4 

 Appendix B to Part 221—Approved Rear End Marking Devices .............................. 6 - 5 

Chapter 7 - Safety Glazing Standards - Locomotives, Passenger Cars & Cabooses – 

Part 223

Guidance ....................................................................................................................... 7 - 1 

Glazing Waivers............................................................................................................ 7 - 1 

Locomotive Glazing...................................................................................................... 7 - 2 

Passenger Equipment Glazing ...................................................................................... 7 - 2 

Chapter 8 - Railroad Locomotive Safety Standards - Part 229

Introduction .................................................................................................................. 8 - 1 

Locomotive Safety Standards Inspection Procedures .................................................. 8 - 2 

 Subpart A---General

§229.1 Scope ................................................................................................. 8 - 3 

§229.3 Applicability ..................................................................................... 8 - 3 

§229.3 Information Collection ...................................................................... 8 - 4 

§229.5 Definitions......................................................................................... 8 - 4 
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§229.7 Prohibited Acts................................................................................ 8 - 11 

§229.9 Movement of non-complying locomotives ..................................... 8 - 12 

§229.11 Locomotive identification ............................................................... 8 - 16 

§229.13 Control of locomotives ................................................................... 8 - 16 

§229.14 Non-MU locomotive control cab locomotives ............................... 8 - 17 

§229.17 Accident reports .............................................................................. 8 - 17 

§229.19 Prior waivers ................................................................................... 8 - 17 

Inspections and Tests 

§229.21 Daily Inspection .............................................................................. 8 - 17 

§229.23 Periodic inspection: General ........................................................... 8 - 21 

§229.25 Tests: Every periodic inspection .................................................... 8 - 24 

§229.27 Annual tests ..................................................................................... 8 - 26 

§229.29 Biennial tests ................................................................................... 8 - 29 

§229.31 Main reservoir tests ......................................................................... 8 - 31 

§229.33 Out-of-use credit ............................................................................. 8 - 32 

§229.41 Protection against personal injury ................................................... 8 - 32 

§229.43 Exhaust and battery gases ............................................................... 8 - 32 

§229.45 General condition ............................................................................ 8 - 33 

Brake System

§229.46 Brakes: General ............................................................................... 8 - 34 

§229.47 Emergency brake valve ................................................................... 8 - 34 

§229.49 Main reservoir system ..................................................................... 8 - 35 

§229.51 Aluminum main reservoirs ............................................................. 8 - 36 

§229.53 Brake gauges ................................................................................... 8 - 37 

§229.55 Piston travel .................................................................................... 8 - 37 

§229.57 Foundation brake gear ..................................................................... 8 - 38 

§229.59 Leakage ........................................................................................... 8 - 38 

Draft System

§229.61 Draft system .................................................................................... 8 - 39 

Suspension System 

§229.63 Lateral Motion ................................................................................ 8 - 40 

§229.64 Plain bearings .................................................................................. 8 - 40 

§229.65 Spring rigging ................................................................................. 8 - 41 

§229.67 Trucks ............................................................................................. 8 - 42 

§229.69 Side bearings ................................................................................... 8 - 42 

§229.73 Wheel sets ....................................................................................... 8 - 42 

§229.75 Wheel and tire defects ..................................................................... 8 - 43 

Electrical System

§229.77 Current collectors ............................................................................ 8 - 45 

§229.79 Third rail shoes ............................................................................... 8 - 45 

§229.85 Doors and cover plates marked "Danger" ....................................... 8 - 46 

§229.89 Jumper; cable connections .............................................................. 8 - 46 

§229.91 Motors and generators..................................................................... 8 - 46 

Internal Combustion Equipment 

§229.93 Safety cut-off device ....................................................................... 8 - 47 

§229.95 Venting ............................................................................................ 8 - 48 
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§229.97 Grounding fuel tanks....................................................................... 8 - 48 

§229.99 Safety Hangers ................................................................................ 8 - 48 

§229.101 Engines ........................................................................................... 8 - 48 

Steam Generators

§229.103 - 113 Steam Generator ................................................................... 8 - 49 

Cabs and Cab Equipment 

§229.115 Slip/slide alarms ............................................................................ 8 - 50 

§229.117 Speed indicators ............................................................................ 8 - 51 

§229.119 Cabs, floors, and passageways ...................................................... 8 - 52 

§229.121 Locomotive cab noise ................................................................... 8 - 55 

§229.123 Pilots, snowplows, end plates ....................................................... 8 - 56 

§229.125 Headlights and auxiliary lights ..................................................... 8 - 57 

§229.127 Cab lights ...................................................................................... 8 - 63 

§229.129 Audible warning device ................................................................ 8 - 63 

§229.131 Sanders .......................................................................................... 8 - 66 

 §229.133 Interim Locomotive Conspicuity Measures .................................. 8 - 66 

 §229.135 Event Recorders ............................................................................. 8 - 66 

 §229.137 Sanitation, general requirements .................................................... 8 - 73 

 §229.139 Sanitation, servicing requirements ................................................. 8 - 77 

Design Requirements

§229.141 Body structure, MU locomotives ................................................ 8 - 81 

Chapter 9 – Steam Locomotives - Part 230

Introduction ................................................................................................................... 9 - 1 

Regulation 49 CFR Part 230 .......................................................................................... 9 - 3 

Part 230 Subpart A---General ........................................................................................ 9 - 3 

 §230.1 Purpose and Scope .............................................................................. 9 - 3 

 §230.2 Applicability ....................................................................................... 9 - 3 

 §230.3 Implementation ................................................................................... 9 - 3 

 §230.4 Penalties .............................................................................................. 9 - 4 

 §230.5 Preemptive Effect................................................................................ 9 - 4 

 §230.6 Waivers ............................................................................................... 9 - 4 

 §230.7 Responsibility for Compliance ........................................................... 9 - 4 

 §230.8 Definitions........................................................................................... 9 - 4 

 §230.12 Movement of Non-Complying Steam Locomotives .......................... 9 - 5 

 §230.13 Daily Inspection ................................................................................. 9 - 6 

 §230.14 Thirty-one (31) Service Day Inspection ............................................ 9 - 7 

 §230.15 Ninety-two (92) Service Day Inspection ........................................... 9 - 8 

 §230.16 Annual Inspection .............................................................................. 9 - 8 

 §230.17 One thousand four hundred seventy-two day (1,472) service day 

inspection .......................................................................................................... 9 - 8 

 §230.18 Service Days ...................................................................................... 9 - 9 

 §230.19 Posting of FRA Form No. 1 and FRA Form No. 3 ............................ 9 - 9 

 §230.20 Alteration and Repair Report for Steam Locomotive Boilers ......... 9 - 10 

 §230.21 Steam Locomotive Number Change ................................................. 9 - 10 
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 Part 230 Subpart B---Boilers and Appurtenances 

 §230.23 Responsibility for General Construction and Safe Working 

Pressure ........................................................................................................... 9 - 10 

 §230.24 Maximum Allowable Stress ............................................................. 9 - 10 

 §230.27 Maximum Shearing Strength of Rivets ............................................ 9 - 10 

 §230.28 Higher Shearing Strength of Rivets .................................................. 9 - 11 

Inspection and Repair 

 §230.29 Inspection and Repair ....................................................................... 9 - 11 

 §230.30 Lap-joint Seam Boilers ..................................................................... 9 - 11 

 §230.31 Flues to Be Removed ........................................................................ 9 - 11 

 §230.32 Time and Method of Inspection ....................................................... 9 - 12 

 §230.33 Welded Repairs and Alterations ....................................................... 9 - 13 

 §230.34 Riveted Repairs and Alterations ....................................................... 9 - 14 

Pressure Testing of Boilers

 §230.35 Pressure Testing ................................................................................ 9 - 14 

 §230.36 Hydrostatic Testing of Boilers ......................................................... 9 - 14 

 §230.37 Steam Test Following Repairs or Alterations...........................9 - 15 

Staybolts

 §230.38 Telltale Holes................................................................9 - 15 

 §230.39 Broken Staybolts............................................................9 - 15 

 §230.40 Time and Method of Staybolt Testing....................................9 - 15 

Steam Gauges

 §230.42 Location of Gauges.........................................................9 - 15 

 §230.43 Gauge Siphon................................................................9 - 15 

 §230.44 Time of Testing.............................................................9 - 15 

 §230.45 Method of Testing..........................................................9 - 15 

 §230.46 Badge Plates................................................................ 9 - 15 

 §230.47 Boiler Number...............................................................9 - 15 

Safety Relief Valves

 §230.48 Number and capacity.......................................................9 - 16 

 §230.49 Setting of Safety Relief Valves...........................................9 - 16 

 §230.50 Time of Testing.............................................................9 - 16 

Water Glasses and Gauge Cocks

 §230.51 Number and Location......................................................9 - 16 

 §230.52 Water Glass Valves........................................................9 - 16 

 §230.53 Time of Cleaning...........................................................9 - 16 

 §230.54 Testing and Maintenance..................................................9 - 16 

 §230.55 Tubular Type Water and Lubricator Glasses and Shields.............9 - 16 

 §230.56 Water Glass Lamps.........................................................9 - 16 

 Injectors, Feedwater Pumps and Flue Plugs. 

 §230.57 Injectors and Feedwater pumps...........................................9 - 16 

 §230.58 Flue Plugs....................................................................9 - 16 

Fusible Plugs. 

 §230.59 Fusible Plugs...............................................................9 - 16 

Washing Boilers 

 §230.60 Time of Washing...........................................................9 - 16 
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 §230.61 Arch Tubes, Water Bar Tubes, Circulators & Thermic Siphons.....9 - 16 

Steam Pipes

 §230.62 Dry Pipe......................................................................9 - 16 

 §230.63 Smoke Box, Steam Pipes and Pressure Parts...........................9 - 16 

Steam Leaks

 §230.64 Leaks Under Lagging......................................................9 - 17 

 §230.65 Steam Blocking View of Engine Crew..................................9 - 17 

Part 230 Subpart C---Steam Locomotives and Tenders

 §230.66 Design, Construction and Maintenance.................................9 - 17 

 §230.67 Responsibility for Inspection and Repairs..............................9 - 17 

Speed Indicators

 §230.68 Speed Indicators............................................................9 - 17 

Ash Pans 

 §230.69 Ash Pans.....................................................................9 - 17 

Brake and Signal Equipment 

 §230.70 Safe Condition..............................................................9 - 17 

 §230.71 Orifice Testing of Compressors...........................................9 - 17 

 §230.72 Testing Main Reservoirs...................................................9 - 17 

 §230.73 Air Gauges...................................................................9 - 17 

 §230.74 Time of Cleaning ...........................................................9 - 17 

 §230.75 Stenciling Dates of Tests and Cleaning..................................9 - 17 

 §230.76 Piston Travel.................................................................9 - 17 

 §230.77 Foundation Brake Gear....................................................9 - 17 

 §230.78 Leakage......................................................................9 - 17 

 §230.79 Train Signal System.......................................................9 - 17 

 

Cabs, Warning Signals, Sanders and Lights 

 §230.80 Cabs..........................................................................9 - 17 

 §230.81 Cab Aprons .................................................................9 - 17 

 §230.82 Fire Doors...................................................................9 - 18 

 §230.83 Cylinder Cocks.............................................................9 - 18 

 §230.84 Sanders.......................................................................9 - 18 

 §230.85 Audible Warning Device..................................................9 - 18 

 §230.86 Required Illumination......................................................9 - 18 

 §230.87 Cab Lights...................................................................9 - 18 

Throttle and Reversing Gear

 §230.88 Throttles.....................................................................9 - 18 

 §230.89 Reverse Gear................................................................9 - 18 

Draw Gear and Draft Systems

 §230.90 Draw Gear Between Steam Locomotive and Tender..................9 - 18 

 §230.91 Chafing Irons................................................................9 - 18 

 §230.92 Draw Gear and Draft Systems.....................................................9 - 18 

Driving Gear

 §230.93 Pistons and Piston Rods...................................................9 - 18 

 §230.95 Guides........................................................................9 - 18 

 §230.96 Main, Side and Valve Motion Rods.....................................9 - 18 
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 §230.97 Crank Pins...................................................................9 - 18 

Running Gear 

 §230.98 Driving, Trailing and Engine Truck Axles..............................9 - 18 

 §230.99 Tender Truck Axles........................................................9 - 18 

 §230.101 Steam Locomotive Driving Journal Boxes.............................9 - 19 

 §230.102 Tender Plain Bearing Journal Boxes...................................9 - 19 

 §230.103 Tender Roller Bearing Journal Boxes.................................9 - 19 

 §230.104 Driving Box Shoes and Wedges.......................................9 - 19 

 §230.105 Lateral Motion............................................................9 - 19 

Trucks, Frames and Equalizing System 

 §230.106 Steam Locomotive Frame................................................9 - 19 

 §230.107 Tender Frame and Body.................................................9 - 19 

 §230.109 Tender Trucks.............................................................9 - 19 

 §230.110 Pilots........................................................................9 - 19 

 §230.111 Spring Rigging............................................................9 - 19 

Wheels and Tires

 §230.112 Wheels and Tires.........................................................9 - 19 

 §230.113 Wheels and Tire Defects................................................9 - 19 

 §230.114 Wheel Centers............................................................9 - 19 

Steam Locomotive Tanks

 §230.115 Feedwater Tanks..........................................................9 - 19 

 §230.116 Oil Tanks....................................................................9 - 19 

Appendix A to Part 230 – Inspection Requirements .............................................................. 9 - 19 

Chapter 10 - Railroad Safety Appliance Standards - Part 231

Introduction ................................................................................................................. 10 - 1 

 Inspection Guidance.................................................................................................... 10 - 4 

(MP&E 98-7) Errors in US DOT Safety Appliance Booklet ..................................... 10 - 4 

(MP&E 98-13) Interpretation of Sill Step Application ............................................... 10 - 5 

(MP&E 98-36) Judgment in the Enforcement of the Safety Appliance Standards ..... 10 - 5 

 Locomotive Applications and Guidance 

 

(MP&E 98-68) Locomotives Used in Switching Service-Location End Handholds . 10 - 7 

(MP&E 98-48) Securement of Handrail to the Locomotive Carbody 

 North American Cab Structure ................................................................................... 10 - 7 

(MP&E 98-25) Burro Crane Requirements ................................................................ 10 - 7 

(MP&E 98-71) Self Propelled Vehicles Considered to Be Locomotives ................... 10 - 8 

 § 231.15 Steam Locomotives Used in Road Service .................................................. 10 - 9 

 § 231.15 Specifications Common to all Steam Locomotives ..................................... 10 - 9 

 § 231.16 Steam Locomotives Used in Switching Service .......................................... 10 - 9 

 § 231.30 Locomotives Used in Switching Service ................................................... 10 - 10 

 § 231.29 Road Locomotives with Corner Stairways ................................................ 10 - 10 
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 Freight & Passenger Car Applications & Guidance 

 

(MP&E 98-14) Safety Appliance Fasteners ............................................................. 10 - 10 

(MP&E 98-22) Adjustable Handhold/Ladder Tread ................................................ 10 - 12 

(MP&E 98-49) Dimensions Applicable to Handles of Uncoupling Levers ............. 10 - 12 

(MP&E 98-51) Definition of Left and Right / A and B end ..................................... 10 - 13 

(MP&E 98-18) Aluminum Safety Appliances ......................................................... 10 - 17 

Handbrakes

(MP&E 98-53) Handbrake Chains ........................................................................... 10 - 17 

(MP&E 98-26) Handbrakes - Articulated Cars ........................................................ 10 - 18 

(MP&E 98-35) Multi-Unit Articulated Flat Cars- Crossover Platforms .................. 10 - 19 

(MP&E 98-5) Standard Level and Low Level Auto Rack Cars ............................... 10 - 19 

Flat Cars

(MP&E 98-16) DODX 4000 Series Flat Cars .......................................................... 10 - 20 

(MP&E 98-69) Safety Appliance Arrangements on Flat Cars ................................. 10 - 20 

(MP&E 00-07) Safety Appliance Arrangements on Flat Cars with Low-Mounted 

Side Hand Brakes ...................................................................................................... 10 - 21 

Covered Hopper Cars 

 

(MP&E 98-23) Covered Hopper Cars - Running Board Extensions ........................ 10 - 22 

 Roof Hatch/Walkway Blockage ............................................................................... 10 - 22 

Cars of Special Construction 

 

(MP&E 98-17) Bulkhead Flat Cars .......................................................................... 10 - 23 

(MP&E 98-19) "Differential" 100-Ton Covered Hopper Cars Built by 

the Thrall Car Mfg Co............................................................................................... 10 - 23 

Safety Appliance Interpretation of Coil Steel Cars................................................... 10 - 23 

Tank Car

 

(MP&E 98-31) Safety Chains on Tank Cars ............................................................ 10 - 25 

(MP&E 00-06) Manufacture and Repair of Operating Platforms and Operating

Platform Safety Railings on Tank Cars without Underframes.................. ........10 - 26 

Chapter 11 - Brake System Safety Standards for Freight & Other Non-Passenger 

 Trains & Equipment: End-of-Train Devices - Part 232

 Introduction ................................................................................................................ 11 - 1 

§232.3 Applicability ............................................................................................. 11 - 3 

§232.5 Definitions.................................................................................................. 11 - 3 
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§232.9 Responsibility for Compliance .................................................................. 11 - 5 

§232.11 Penalties ..................................................................................................... 11 - 6 

§232.15 Movement of Defective Equipment ........................................................... 11 - 6 

§232.17 Special Approval Process .......................................................................... 11 - 9 

§232.103 General Requirements for All Train Brake Systems ................................. 11 - 9 

§232.105 General Requirements for Locomotives ................................................. 11 - 13 

§232.107 Air Source Requirements ........................................................................ 11 - 13 

§232.109 Dynamic Brake Requirements ................................................................ 11 - 14 

§232.111 Train Handling Information .................................................................... 11 - 16 

§232.203 Training Requirements ............................................................................ 11 - 16 

§232.205 Class I Test Initial Terminal Inspection .................................................. 11 - 17 

§232.207 Class IA Brake Tests - 1,000 Mile Inspection ........................................ 11 - 26 

§232.209 Class II Brake Test - Intermediate Inspection ......................................... 11 - 27 

§232.211 Class III Brake Test - Trainline Continuity Inspection ........................... 11 - 28 

§232.213 Extended Haul Trains ............................................................................. 11 - 28 

§232.215 Transfer Train Brake Tests ..................................................................... 11 - 29 

§232.217 Train Brake System Tests Conducted Using Yard Air ........................... 11 - 29 

§232.219 Double Heading and Helper Service ....................................................... 11 - 30 

Subpart D Periodic Maintenance and Testing Requirements ................................. 11 - 30 

(MP&E 98-63) Subpart E End-of-Train Devices ................................................... 11 - 32 

(MP&E 98-62) Two-Way End-of-Train Device Flow Chart ................................... 11 - 38 

 Subpart G – Electronically Controlled Pneumatic (ECP) Brake Systems ................ 11 - 40 

§232.602 Applicability ............................................................................................ 11 - 46 

§232.605 Training Requirements ............................................................................. 11 - 46 

§232.607 Inspection and Testing requirements ....................................................... 11 - 46 

§232.609 Handling of defective equipment with ECP brake systems ..................... 11 - 48 

§232.611 Periodic maintenance ............................................................................... 11 - 50 

§232.613 End-of-Train (EOT) devices .................................................................... 11 - 50 

Guidance for Appendix B to Part 232 – Part 232 Prior to May 31, 2001 as Clarified 

Effective April 10, 2002 ........................................................................................... 11 - 51 

(MP&E 98-59) Train Brake Inspection ................................................................... 11 - 51 

(MP&E 98-45) Initial Terminal Air Brake Tests at Remote Locations ................... 11 - 52 

(MP&E 99-01) Clarification for Initial Terminal Road Train Air Brake Tests ....... 11 - 52 

(MP&E 00-01) Enforcement Guidance for Inspecting & Testing Brakes on Cars on Shop 

 or Repair Tracks ....................................................................................................... 11 - 53 

(MP&E 98-40) 1,000-Mile Interpretation - 49 CFR §232.12(b) ............................. 11 - 54 

(MP&E 98-46) Hauling of Defective Cars at Intermediate Inspection Locations ... 11 - 54 

 U.S.C. §20303 .......................................................................................................... 11 - 56 

(MP&E 98-6) Bottom Rod Safety Support .............................................................. 11 - 57 

(MP&E 98-8) Air Brake System - Reservoir Connecting Pipes .............................. 11 - 57 

(MP&E 98-11) Testing of Handbrakes on Locomotives Equipped with 

 an Air Release Valve ............................................................................................... 11 - 57 

(MP&E 98-15) Air Flow Method as an Alternative to Leakage Tests for Trains ... 11 - 57 

(MP&E 98-27) Locomotive Handbrakes - Stencil Requirements for

Canadian Railroads .................................................................................................. 11 - 59 

(MP&E 98-41) Locomotive Brake Cylinder Pressure ............................................. 11 - 59 
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(MP&E 98-55) Brake Hoses on Cars Equipped with 15" End-of-Car 

 Cushioning Units ...................................................................................................... 11 - 60 

(MP&E 98-56) Sloan Model 3050-A and 3200-A Angle Cocks ............................. 11 - 60 

 Guidance on truck mounted brakes and indicators .................................................... 11 - 62 

Chapter 12 - Passenger Equipment Safety Standards - Part 238

§238.3 Introduction ................................................................................................ 12 - 1 

 §238.5 Applicability ............................................................................................... 12 - 2 

 §238.5 Definitions................................................................................................... 12 - 2 

 §238.5 Private Railcars Regulatory Compliance: Q&A ......................................... 12 - 4 

 §238.9 Responsibility for Compliance ................................................................... 12 - 5 

 §238.15 Movement of Passenger Equipment with Power Brake Defects ................ 12 - 6 

 §238.17 Movement of Pass. Equipment with Other Than Power Brake Defects ..... 12 - 7 

 §238.109 Training Qualification, and Designation..................................................... 12 - 7 

 §238.119 Rim-Stamped Straight Plate Wheels ........................................................... 12 - 8 

 §238.303 Exterior Calendar Day Mechanical Inspection of Pass. Equip ................... 12 - 8 

 §238.305 Interior Calendar Day Mechanical Inspection of Cars ............................... 12 - 9 

 §238.307 Periodic Mechanical Inspections ................................................................ 12 - 9 

(MP&E 07-02) Guidance for Record Keeping of Annual Periodic Inspection 

 of the Hand or Parking Brake on Passenger Cars and Unpowered Vehicles 

 Used in Passenger Trains, 49 CFR Section 238.307(d)(2).. ..................................... 12 – 10 

 §238.309 Periodic brake equipment maintenance .................................................... 12 - 10 

 §238.311 Single Car Test .......................................................................................... 12 - 11 

 §238.313 Class I Brake Test ..................................................................................... 12 - 12 

 §238.315 Class IA Brake Test .................................................................................. 12 - 12 

 §238.317 Class II Brake Test ................................................................................... 12 - 14 

 §238.503 Inspection, Testing and Maintenance Requirements ................................ 12 - 15 

Chapter 13 - Passenger Train Emergency Preparedness - Part 239 

Guidance to be developed and published in the near future. 

Chapter 14 - Reflectorization of Rail Freight Rolling Stock - Part 224

 Introduction ................................................................................................................. 14 - 1 

 §224.107(a)(1) Implementation schedule ................................................................... 14 – 1 

 §224.107(a)(2)(i) Existing cars without retroreflective sheeting ................................ 14 – 1 

 §224.5 Definitions....................................................................................................... 14 – 2 

 §224.106 Location of retroreflective sheeting ............................................................ 14 – 2 

 §224.105 Sheeting dimensions and quantity .............................................................. 14 – 3 

 §224.103 Characteristics of retroreflective sheeting .................................................. 14 – 3 
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Chapter 15 - Guidelines for Enforcement of Mechanical Requirements for Rail Grinding 

Equipment 

 Introduction ................................................................................................................. 15 - 1 

Guidelines for Enforcement of Mechanical Requirements ......................................... 15 - 1 

 Guidelines for Enforcement of Roadway Maintenance Machine Requirements ........ 15 - 3 

Guidelines for Enforcement of Operating Practices Requirements ............................ 15 - 3 

 Application of 49 CFR Part 214, Subpart D ............................................................... 15 - 4 

Chapter 16 - Wayside Detector/Train Inspection Guidance

AAR and Class I Railroad Initiatives.......................................................................... 16 - 1 

 Future Considerations for Wayside Detectors ............................................................ 16 - 4 

Waiver(s) Issued ......................................................................................................... 16 - 5 

Wayside Detector Glossary of Terms ......................................................................... 16 - 5 

Wayside Detector Treaties .......................................................................................... 16 - 7 

Preliminary Guidance for Interpreting Wayside Detector Data in Derailment Cause

 Finding / Prevention Related to Car/Equipment Only .............................................. 16 - 24 

Appendix A - Instructions for Completing MP&E Violation Reports

The RISPC Program, F6180.96 and Forms F6180.109; F6180.67 Forms .................. A - 2 

 Submission of Photographs as Evidence ..................................................................... A - 2 

Statements of Witness or Reports of Interview ........................................................... A - 2 

 Copies of Railroad’s Records ...................................................................................... A - 2 

Digital Violation Master File ....................................................................................... A - 3 

Case Type List ............................................................................................................. A - 3 

List of Exhibits Requirements ..................................................................................... A - 4 

Identification of Exhibits ............................................................................................. A - 4 

Sequence of Master Digital Violation.......................................................................... A - 4 

PDF Violation Package – Bookmarking Documents................................................... A - 4 

 Violation Package ........................................................................................................ A - 4 

Digitally Signing the Completed violation Package .................................................... A – 5 

Motive Power & Equipment Violation Report Form F 6180.109 ............................... A - 5 

Digital Violations FAQ .............................................................................................. A - 12 

 

Appendix B - Waivers - MP&E Related

Electronic Locomotive Brakes

EPIC Locomotive Brakes 2002-13397 (Formerly H-92-3) .............................. B - 1 

CCB Locomotive Brakes 2000-7367 (Formerly H-95-3 .................................. B - 2 

 CSX Transportation - CCB Test Waiver 1999-6252 ........................................ B - 4 

 Amtrak Electronic Brakes for HHP8 Electric Locomotives 2001-10596 ........ B - 5 

Locomotive Brakes

 AAR 26-L Brake 1,104 days to 48 Months 2005-21325.. ................................ B - 6 

 Locomotive Record-Keeping 
Motive Power and Equipment Compliance Manual

xiii

 Electronic Daily Inspection - BNSF Railway Company 2000-7782 ................ B - 7 

 Electronic Daily Inspection - Union Pacific Railroad 2001-11014 .................. B - 8 

 Electronic Daily Inspection - Norfolk Southern Corp. 2005-22822 ................. B - 9 

 Electronic Blue Card - BNSF Railway Company 2003-16440 ...................... B - 11 

 Electronic Blue Card - Canadian National Railway 2004-18960 ................... B - 11 

 Electronic Blue Card - Union Pacific Railroad 2004-17308 .......................... B - 11 

Electronically Controlled Pneumatic (ECP) Brake Requirements 

 BNSF and NS 2006-26435 ............................................................................. B - 12 

Blue Signal

 BNSF - Two-Way EOT - Removal & Replacement of batteries by Train and 

 Yard Crew Members and Utility Employees 2001-10660 ............................. B - 15 

Two-Way End-of-Train Device

 TrainLink II - ATX EOT Telemetry With Power Supplied by An Air 

 Generator 2001-9270 ...................................................................................... B - 16 

 Quantum EOT 2006-25794............................................................................. B - 18 

 TrainLink II Head of Train Device (HTD) ......................................................B - 19 

 American Short Line Regional Railroad Association - Restrictions on 

 Heavy Grade Operation without Two-Way EOT PB-97-12 ......................... B - 20 

 Passenger Equipment Standards 

 Passenger Brakes ............................................................................................ B - 21 

 AAPRCO 2003-15340 .................................................................................... B - 21 

Highway Rail Vehicles Such As RoadRailers®, RailRunner®, Etc.

 BNSF Railway Company 1999-5895 ............................................................. B - 22 

 CN/IC Railroad 2000-8089 ............................................................................. B - 26 

 NS Corporation 2002-11896 ........................................................................... B - 28 

 CSX Transportation SA-87-4 & PB-87-5 ....................................................... B - 32 

 Texas Mexican Railway 2000-7040 ............................................................... B - 34 

Safety Appliances

 NS Corporation 2008-0029............................................................B - 37 

CSX Transportation 2008-0039......................................................B - 38 

Twin Cities & Western Railroad 2008-0154.......................................B – 39 

Escanaba & Lake Superior Railroad Company 2008-0155......................B - 41 

Canadian Pacific Railroad 2008-0163..............................................B - 43 

Appendix C - Safety Appliance Plates - Locomotives

Illustrative Locomotive Plates

Plate "S-1" Steam Locomotives used in Switching Service ................................................C - 1 

Plate "S-2" Tenders of Steam Locomotives used in Switching Service .............................. C - 1 

Plate "S-3" Steam Locomotives used in Road Service ........................................................ C - 2 

Plate "S-4" Tenders of Steam Locomotives used in Road Service...................................... C - 2 

Plate "S-5" Tenders of Vanderbilt Type .............................................................................. C - 3 
Federal Railroad Administration

xiv

Appendix D - Safety Appliance Plates - Freight Cars

Illustrative Freight Car Plates

Plate A - Handbrake ..................................................................................................... D - 1 

Plate B - Couplers ........................................................................................................ D - 2 

Plate C - Box & Other House Cars .............................................................................. D - 3 

Plate D - Box & Other House Cars with platform end sills ......................................... D - 4 

Plate E - Hopper Cars & High Side Gondolas with fixed ends ................................... D - 5 

Plate F - Hopper Cars & High-Side Gondolas with fixed ends ................................... D - 6 

Plate G - Drop-End High-Side Gondola Cars .............................................................. D - 7 

Plate H - Drop-End High-Side Gondola Cars with platform end sills ......................... D - 8 

Plate I - Fixed-End Low-Side Gondola & Low-Side Hopper Cars ............................. D - 9 

Plate J - Fixed-End Low-Side Gondola & Low-Side Hopper Cars with end sills ..... D - 10 

Plate K - Drop End Low-Side Gondola Cars ............................................................. D - 11 

Plate L - Drop-End Low-Side Gondola Cars with platform end sills ........................ D - 12 

Plate M - Flat Cars ..................................................................................................... D - 13 

Plate N - Tank-Cars with Side Platforms ................................................................... D - 14 

Plate O - Tank Cars without side sills & Tank Cars short side sills & end platforms D - 15 

Plate P - Tank Cars without End-Sills ....................................................................... D - 16 

Plate Q - Caboose Cars with Platforms...................................................................... D - 17 

Plate R - Caboose Cars without Platforms ................................................................. D - 18 

Plate S - Tank Cars without Underframes ................................................................. D - 19 

Plate T - Box & Other House Cars with Roofs > 10 inches above top of rail ........... D - 20 

Plate U - Box & Other House Cars without Roof Hatches ........................................ D - 21 

Plate V - Box & Other House Cars with Roof Hatches ............................................. D - 22 

Appendix E – Statistically Driven Inspection Guidance for MP&E Inspectors & Safety 

Specialists

Overview ....................................................................................................................... E - 2 

 Background ................................................................................................................... E - 2 

Applicability ................................................................................................................. E - 2 

Pilot Project ................................................................................................................... E - 4 

Pilot Project Summary .................................................................................................. E - 2 

“Drill-down” Procedure ................................................................................................ E - 5 

Focused Enforcement.................................................................................................... E - 7 

 Interpretation of the Nationwide Mechanical Equipment Accident/Incident 

Statistics & Trends (Bi-annual Report)......................................................................... E - 8 
1 – 1 

Chapter 1 

General Information 

Introduction

The Motive Power and Equipment Compliance Manual (Compliance Manual) provides guidance 

to Federal and State Motive Power & Equipment (MP&E) inspectors that ensure compliance 

with Federal safety laws. Findings of noncompliance with Federal safety laws may result in 

enforcement action and civil penalty. Discussions of the safety standards in this manual provide 

interpretations and policies related to specific regulatory sections. The information contained in 

this manual does not modify, alter, or revise Federal law. This manual is the property of the 

Federal Railroad Administration (FRA) and is intended to be used by only FRA personnel. The 

information in this manual is intended to provide internal guidance and does not provide any 

basis for a private party to challenge FRA’s exercise of enforcement discretion in a particular 

case. The contents of this manual may be revoked or modified without prior notice at any time 

by FRA. This manual supersedes all previous MP&E Enforcement Manuals. 

This manual is a complement to the Office of Railroad Safety’s General Manual, as revised in 

August 2009. The General Manual provides detailed information regarding FRA’s overall 

operations, history and statutory authority, rulemaking process, and inspection and investigation 

procedures. Both manuals are specifically intended for the safety inspectors and technical 

specialists throughout the country who monitor compliance with Federal safety laws and 

standards that apply to the railroad industry. Using both manuals will achieve uniformity and 

consistency, as well as enable FRA’s front-line representatives to successfully promote the 

agency’s safety mission. 

Inspectors should use the Compliance Manual as an aid to help gain a better understanding of the 

laws governing the safety of railroad rolling equipment. However, having a thorough knowledge 

and understanding of the laws and regulations alone is not enough to be a good inspector. The 

success and effectiveness of FRA’s safety assurance and compliance programs hinge on the 

ability of the inspector to use good judgment and strategies with the railroad industry, so that 

compliance with the regulations is achieved. Inspectors have considerable enforcement 

discretion and this manual should be used to guide the individual on how to exercise that 

discretion. If the manual does not provide adequate guidance for a particular situation, or if there 

is any doubt as to the meaning of any of the information provided in this manual, the inspector 

should seek the assistance of the regional MP&E specialist. 

Compliance with the directives in this manual will result in uniform application and enforcement 

of federal laws and safety regulations throughout the Nation. This uniformity is necessary for 

effective program management and is mandated by the Federal Railroad Safety Act of 1970 

(P.L. 91-458). These directives will also help to achieve maximum effective use of the limited 

available resources. 

All activities shall be conducted in accordance with the FRA’s Goals of improving railroad 

safety contained in the General Inspection Principles in Chapter 3 of the General Manual. 
Federal Railroad Administration 

1 – 2 

Questions about information or interpretations contained in this manual should be referred to the 

MP&E Headquarters Staff (RRS-14) for a prompt response. Suggested improvements or 

corrections to the manual should also be submitted to regional specialists, who will then forward 

them to RRS-14. 

Program Goals

The goal of the MP&E inspection program is to administer an effective safety program and to 

achieve safe operating and mechanical practices in the railroad industry, through compliance 

with all Federal laws that are designed to promote railroad safety as it relates to employees, 

passengers, and the general public. The MP&E inspection program is primarily responsible for 

monitoring compliance for the following railroad safety regulations, found in Title 49 Code of 

Federal Regulations (CFR): 

 Part 210 - Railroad Noise Emission Compliance Regulations 

 Part 215 - Railroad Freight Car Safety Standards 

Part 218 - Railroad Operating Practices 

 Subpart B - Blue Signal Protection of Workers 

 Subpart D – Prohibition Against Tampering with Safety Devices 

Part 221 - Rear End Marking Device - Passenger, Commuter and Freight Trains 

Part 223 - Safety Glazing Standards - Locomotives, Passenger Cars, and 

 Cabooses 

 

Part 224 – Reflectorization of Rail Freight Rolling Stock 

 Part 229 - Railroad Locomotive Safety Standards 

 Part 230 - Steam Locomotive Inspection and Maintenance Standards 

 Part 231 - Railroad Safety Appliance Standards 

Part 232 - Brake System Safety Standards for Freight and Other Non-Passenger 

 Trains and Equipment: End-of-train Devices 

 Part 238 - Passenger Equipment Safety Standards 

 Part 239 - Passenger Train Emergency Preparedness 

 §239.101(6) On-board Emergency Equipment 

 §239.107 Emergency Exits 
Motive Power and Equipment Compliance Manual 

1 – 3 

Basis for Regulation and Inspection

The Statutory authority for the regulations and inspections conducted by the MP&E inspectors 

comes from various Acts of the United States Congress. For a detailed discussion on this 

authority please read the Brief History and Organization of the Federal Railroad Administration 

in Chapter 1 of the General Manual. 

Definitions and Roles

Specialist: As used hereafter in this manual, refers specifically to regional MP&E railroad 

safety specialists. The specialist is responsible for technical evaluation and oversight of all 

motive power and equipment inspections, analyses, and activities within the region and provides 

technical guidance, training, and advice in the MP&E areas. Headquarters specialists are subject 

to the same requirements and guidance of this manual. 

Inspector: As used hereafter in this manual, refers to a Federal MP&E inspector or a qualified 

State equipment inspector. Inspectors are the front-line representatives of the agency and must 

be thorough while conducting themselves in a safe, professional, ethical, and courteous manner. 

State Equipment Inspector: As used hereafter in this manual refers to either a qualified State 

car inspector, qualified State locomotive inspector, or qualified State MP&E inspector who has 

been certified by the FRA to conduct equipment inspections in a Participating State. 

Stakeholders: Includes those the agency regulates as well as those it serves. Some partner with 

FRA to develop safety initiatives and technology, while others help review, develop, and/or 

enforce FRA’s safety regulations. All stakeholders depend on FRA to fulfill its mission to 

promote a safe, environmentally sound, successful railroad transportation to meet current and 

future needs. 

Credentials

Inspectors must have their credentials on their person while on duty. Any request to provide 

identification should be complied with in a prompt and courteous manner. Inspectors should not 

permit their credentials to be photocopied. Additionally, inspectors are encouraged to obtain and 

provide business cards to stakeholders, as conditions warrant. Inspectors should consult with 

their supervisors on procedures for procuring the cards, as conditional reimbursement is 

permitted. 

Personal Safety

The inspector’s first concern is for his or her own safety and that of any accompanying 

personnel. Inspectors should always remain alert to the dangers of moving equipment and third 

rail/electrified equipment. 

Inspectors must comply with any railroad’s request to use safety equipment, such as hard hats, 

safety shoes, safety glasses, etc. Inspectors should also comply with all of the railroad’s safety 
Federal Railroad Administration 

1 – 4 

rules, to the extent that it would not materially interfere with FRA’s capability to conduct 

investigations. FRA inspectors are not required to establish blue signal protection while 

conducting inspection activities. 

Inspectors should read and be familiar with the Federal Railroad Administration Safety Policy, 

Procedures, and Recommendations. Copies of this pamphlet are available either from your 

regional or Headquarters managers, or from an FRA industrial hygienist, as well as in the REGTrieve program. 

Recommended Safe Work Procedures

Each inspector is encouraged to refer to a booklet published by the FRA called Recommended 

Safe Work Procedures to assist in the performance of his/her duties. By adhering to the 

information contained in the booklet, staying alert, and never taking your work environment for 

granted, you will reduce injury to yourself and others. Work procedures and practices are 

defined as the suggested safe way to perform a job. The potential for injuries increases when 

the prescribed procedures are not properly followed. 

Rules and regulations are nothing new to us. FRA has compiled a comprehensive set of safe 

work procedures for the inspector to follow in the day-to-day work activities. They were 

developed from a study of existing railroad safety rules, and by FRA colleagues in their 

participation in the various Job Safety Analysis activities. If the information in the booklet is not 

clear or if it does not provide enough material to make a sound decision, the inspector should 

contact the Collateral Duty Officer or a supervisor for additional guidance. Remember, no job is 

so important and no service is so urgent that we cannot take time to perform all work safely. 

Technical Bulletins

The Office of Safety Assurance and Compliance periodically issues Technical Bulletins (TBs) to 

provide instructions and guidance on a variety of general and discipline-oriented issues. 

MP&E inspectors must maintain a current file of all general and MP&E-related TBs, which must 

be readily available to them. It is suggested that current TBs be kept with this manual. 

Contacts With News Media

Inspectors are not authorized to grant interviews or respond to representatives of the news media 

regarding FRA activities. If approached by news media personnel, inspectors should refer such 

personnel to FRA’s Office of Public Affairs (202-493-6024) for handling. This applies to all 

news organizations including television and radio news stations, as well as newspapers, 

magazines, Web-based news outlets, and academic. Additionally, this applies to all industry 

trade publications. Inspectors must not provide the news media with information or opinions 

as to a probable cause of an accident or incident. 

Any requests for information, made under the Freedom of Information Act, should be forwarded 

to the FRA Office of Chief Counsel. 
Motive Power and Equipment Compliance Manual 

1 – 5 

See Contacts with News Media under Communication Guideline in Chapter 4 of the General 

Manual for more guidance regarding requests for information. 

Cooperation of FRA Personnel with Industry, Labor, and Other Agencies

The inspector should maintain a cordial relationship with the railroads, manufacturers of railroad 

equipment, labor union personnel, and other public or governmental agencies. The inspector 

must obtain authority from his/her regional supervisor or their representative before cooperation 

or participation in any project with any of the aforementioned groups or individuals is conducted. 

Subpoenas

Please read the Responding to Subpoenas and Other Requests for Information or 

Testimony in Chapter 2 of the General Manual which provides important information regarding 

responding to requests and demands to testify or produce documents to outside parties. 

Additionally, it is important to know that, if subpoenaed or otherwise notified to appear as a 

witness in any court proceeding, inspectors must immediately notify their regional office and 

provide information as to the date, place and time of the subpoena served; title of case; party by 

whom subpoenaed; name and address of that party’s attorney; name of court; place, date and 

time of trial, and circumstances of the incident for which subpoenaed. This also applies to 

railroad disciplinary investigations. The inspector must not respond to any of these requests 

independently. 

Operating Equipment

An inspector shall never operate any piece of railroad equipment. There is no exception to this 

rule! However, an inspector may request that a railroad representative move or operate a piece 

of equipment, or perform a test for investigation purposes. 

Delaying Trains

Inspectors have no authority to prohibit the departure or movement of any train, locomotive, car, 

etc. Inspectors can issue a Special Notice for Repairs and should point out any hazardous 

conditions that could result in an accident should the defective train, locomotive, or car depart 

without appropriate attention. If a railroad elects to move equipment without taking appropriate 

action, the inspector should notify their regional office immediately and develop information to 

pursue civil penalties against the railroad and/or initiate enforcement action against an 

individual. Especially, if a Special Notice for Repairs has been issued and ignored. 

Please also read Intervening When Railroad Employees Perform Unsafe Acts in Chapter 2 of 

the General Manual. 
Federal Railroad Administration 

1 – 6 

Unusual Occurrences

Please read Handling Deterrents to Inspections in Chapter 2 of the General Manual. 

National Transportation Safety Board

Please read the National Transportation Safety Board (NTSB) section in Chapter 4 of the 

General Manual for guidance. 

The “Independent Safety Board Act of 1974” established the National Transportation Safety 

Board (NTSB) as an independent agency. The NTSB is authorized to investigate railroad 

accidents and make recommendations based upon the findings of their investigations. If NTSB 

Investigators arrive on the scene during an accident investigation, FRA inspectors should 

introduce themselves and promptly contact the regional office to advise of the NTSB’s presence. 

However, unless instructed otherwise, FRA investigation activities should continue 

independently. 

It is the Office of Railroad Safety’s policy to extend full cooperation to the NTSB in all matters 

related to railroad safety and accident investigation. If an inspector is assigned to assist in an 

NTSB accident investigation, the inspector must keep the Regional Administrator informed 

about the progress of the NTSB’s investigation. 
2 – 1 

Chapter 2 

Inspection and Compliance Program

Introduction

The General Manual provides detailed information regarding general inspection and 

investigative procedures, along with a good discussion about the rulemaking process. However, 

there are some policies and procedures that are specific to the MP&E Discipline and warrant 

inclusion in this manual. 

Allocation of Resources

The regional supervisors, including the MP&E specialist, are responsible for coordinating 

special MP&E assignments and activities within the region using national and regional safety 

data to allocate inspector resources. The regional supervisors, through the MP&E specialist, 

shall establish priorities appropriate to the urgency and seriousness of any alleged complaint, 

violation, or incident. 

Inspectors are responsible for coordinating daily inspection activities to ensure adequate 

coverage of their territory. The inspector should plan to visit all assigned inspection points 

within their territories as circumstances warrant, unless directed otherwise by regional 

management. 

Regular Inspection Point

Each inspector will prepare and maintain an accurate regular inspection point (RIP) list of 

inspection points for railroads within his/her assigned territory. The RIP list, and any subsequent 

changes to the list, shall be forwarded to the regional specialist. The specialist is responsible for 

reviewing regional RIP lists for accuracy. 

Inspection/Activities Priorities

The allocation of resources will often deviate from the desired goal because of unforeseen 

events. When these events occur, Regional Administrators, Deputy Regional Administrators, 

specialists and inspectors will base their decisions on the following priorities: 

1. Accident investigations 

2. Congressional complaint investigations 

3. Waiver petition investigations 

4. One-time movement investigations (receives higher priority if the OTM is for 

clearing major accident site) 

5. Regular complaint investigations 
Federal Railroad Administration 

2 - 2 

6. National Safety Program Plan (NSPP) inspection 

7. Focused enforcement inspection 

8. Sample locomotive/car inspections 

9. Steam locomotive - Boiler inspections 

10. Site-Specific (Routine) inspections 

11. Operation Life Saver presentations 

Accident Investigations

Refer to the Accident Investigation Guidelines in Chapter 4 of the General Manual, for agency 

policies and procedures. The following resources are available for assessing commodity hazards 

and rail equipment damage and can be provided to the On-Scene Coordinator: 

Emergency Assistance: 

Chemtrec 800-424-9300 

Chlorep 703-527-3887 

NACA Pesticide Safety 888-663-2155 

Bureau of Explosives 202-639-2910 

Poison Control Center 800-222-1222 

National Response Center 800-424-8802 

FEMA 202-646-2044 

Nuclear Regulatory Commission 301-951-0550 

Transportation Crisis Mgt Center 202-366-5270 

FRA Public Affairs Office 202-493-6024 

 

Congressional Complaints Inspections

Refer to the Compliant Investigations of Chapter 5 in the General Manual. Remember, the 

inspector has 10 days to complete the investigation and submit a written report of the findings to 

the regional office. 

Waiver Petition Investigations

All MP&E waiver petitions must be processed through the Washington, DC, headquarters 

Office. Headquarters will assign a Docket Number and publish the request in the Federal 

Register and transmit the request to the region for investigation. The region will then assign the 

waiver petition to an inspector for investigation. Waiver petitions are handled pursuant to Title 

49 CFR Part 211, which states that waiver decisions must be made not later than 9 months after 

receipt of the request. Therefore, the waiver investigation must be conducted in a timely manner. 
Motive Power and Equipment Compliance Manual 

2 – 3 

The inspector will prepare an Inspector Report Form for MP&E Petitions and submit it to the 

regional office within 30 days. If the waiver petition investigation requires more than 30 days to 

complete, the inspector will submit a memorandum or e-mail to the regional office detailing the 

reason for the delay. All recommendations from the inspector and region must be supported with 

factual evidence, proof, and/or data, not opinions. CAUTION: The inspector should never 

disclose to the petitioner what the recommendation will be, as the Railroad Safety Board has the 

final say. 

Refer to the Waiver Investigations including Signal Applications in Chapter 5 of the General 

Manual for more details of the waiver process. 

Inspectors shall use the Form “Inspector Report Form for MP&E Petitions” shown below to 

report the findings of his/her investigation. 

DEPARTMENT OF TRANSPORTATION

FEDERAL RAILROAD ADMINISTRATION

Inspector Report Form for MP&E Petitions

Petition No. Date Petition Filed

Inspector Date of Report 

Railroad/Co. Filing Petition 

Inspection/Investigation Date Location 

Railroad/Co. Representative Name & Title 

Synopsis of Petition and Inspector Recommendation 

 

Furnish the Following Information - (choose one only with X for (a))

(a) Description of proposed changes or relief sought, locations with respect to place 

and distance between designated points is correctly stated in Public Notice, or

should be changed to read as follows.

 

(b) Name of any other railroads affected by proposed changes not shown in Public 

Notice and manner in which affected.
Federal Railroad Administration 

2 - 4 

(c) 1) Description of motive power or equipment involved. 

2) Describe condition of motive power or equipment involved relative to 

compliance with 49 CFR Part(s) 215, 223, 229, 230, 231, 232 or 238. 

3) Description of operations for which waiver of compliance is sought. 

4) Information relative to the proposed relief not fully described in the Public 

Notice. 

5) Present method of operation, number of trains or other movements per day, 

and speed authorizations and restrictions. 

6) Summary of accidents/incident reports reviewed relative to proposed relief. 

7) Other pertinent facts or remarks. 

(d) List of any prints, bulletins, orders, timetables, etc., obtained during 

investigation.

(e) List the specific sections from which relief are sought (e.g. 49 CFR Part 223, 

229). 

1) Reason(s) proposed relief from compliance with the regulations is necessary. 

2) If any of the proposed changes have been placed in service, give description of 

such changes, date such changes were placed in service and the reasons for 

making the changes before approval of the petition. 

(f) Inspector analysis - The proposed relief will (choose one only with X for (f)) 
Motive Power and Equipment Compliance Manual 

2 – 5 

Reduce protection and safety.

Provide adequate protection for existing and operating conditions without 

materially reducing safety.

Maintain existing protection and safety.

Increase protection and safety.

State Reasons:

(g) Inspector's recommendation regarding disposition of this application, (explain 

and state reasons).

One-Time Movement Inspections 

From time to time, railroads or equipment owners will request that FRA issue a “one-time 

movement authority” (OTM) to allow a noncomplying cars or locomotives to be moved for a 

specific purpose under specified conditions ensuring for safety of the movement. It should be 

noted that FRA considers an OTM to be an exercise of its enforcement discretion in a limited 

number of specialized circumstances, and the granting of such authority does not relieve a party 

from any statutory liability applicable to such movements. 

This authority is not necessary for equipment that can be moved under 49 CFR § 215.9, § 229.9, 

or §§ 238.15 & .17 authority. FRA will consider granting OTM movement authority on the 

following basis: 

 Positioning - For example, an over-age car or noncomplying locomotive being moved to 

a railroad museum for permanent display, or noncomplying equipment moved to ports for 

shipment to a foreign country. 

 Dismantling - A wreck-damaged car or locomotive that is deemed to be not economically 

repairable, or an over-aged or retired car or locomotive that needs to be moved to a scrap 

yard for dismantling. 

 Repair - Movement for repair requests are the most common, and also the most often 

denied of the four categories. For FRA to consider issuing authority for movement of 

noncomplying equipment for repair, the circumstances related to the movement must be 

unique and/or the necessary repairs must require specialized facilities or personnel skills. 

For example, the nearest facility may not be equipped to fully effect the necessary 

repairs, such as heavily wreck-damaged locomotives or tank cars. 

 Prototypes - Special demonstrations and testing of prototype equipment. 
Federal Railroad Administration 

2 - 6 

To obtain one-time movement authority from FRA, the requestor must submit a letter on 

company letterhead to: 

Director 

Office of Safety Assurance and Compliance 

1200 New Jersey Avenue, SE, 

West Building, Third Floor, Mail Stop 25 

Washington, DC 20590 

If the OTM is strictly within the boundaries of a single FRA region (considered a “RegionalLocal” OTM), the petitioner may submit the request to the attention of the Regional 

Administrator of the particular region, as follows: 

FRA REGIONAL OFFICE ADDRESSES: 

Regional Administrator 

Federal Railroad Administration, Region 1 

55 Broadway, Room 1077 

Cambridge, MA 02142 

(617) 494-2302 

(617) 494-2967 FAX 

(800) 724-5991 

Regional Administrator 

Federal Railroad Administration, Region 2 

Baldwin Tower, Suite 660 

1510 Chester Pike 

Crum Lynne, PA 19022 

(610) 521-8200 

(610) 521-8225 FAX 

(800) 724-5992 

Regional Administrator 

Federal Railroad Administration, Region 3 

Atlanta Federal Center 

61 Forsyth Street, S.W, Suite 16T20 

Atlanta, GA 30303-3104 

(404) 562-3800 

(404) 562-3830 FAX 

(800) 724-5993 

Regional Administrator 

Federal Railroad Administration, Region 4 

200 West Adams Street, Suite 310 

Chicago, IL 60606 

(312) 353-6203 

(312) 886-9634 FAX 

Regional Administrator 

Federal Railroad Administration, Region 5 

4100 International Plaza, Suite 450 

Fort Worth, TX 76109 

(817) 862-2200 

(817) 862-2204 FAX 

(800) 724-5995 

Regional Administrator 

Federal Railroad Administration, Region 6 

901 Locust Street, Suite 464 

Kansas City, MO 64106 

(816) 329-3840 

(816) 329-3867 FAX 

(800) 724-5996 

Regional Administrator 

Federal Railroad Administration, Region 7 

801 I Street, Suite 466 

Sacramento, CA 95814 

(916) 498-6540 

(916) 498-6546 FAX 

(800) 724-5997 

Regional Administrator 

Federal Railroad Administration, Region 8 

500 East Broadway, Suite 240 

Vancouver, WA 98660 

(360) 696-7536 

(360) 696-7548 FAX 

(800) 724-5998 

(800) 724-5040 
Motive Power and Equipment Compliance Manual 

2 – 7 

All request letters must contain the following information: 

 The reporting mark/number and the type of equipment (e.g. locomotive, covered hopper 

car, passenger car), for which the OTM is requested, along with the corresponding 

Federal Safety Regulation [e.g., 49 CFR § 215.203(a)(1) Restricted Cars]. 

 The status of the equipment, to include all noncomplying components. State the cause of 

any damage (e.g., collision/sideswipe, grade crossing collision, derailment). Also, 

address any precautions taken to ensure the safety of railroad personnel during the move, 

such as removal of sharp edges, loose or crushed components, addition of temporary 

safety appliances and/or caution tape, roped-off stairway, etc. 

 The point of origin and final destination of the equipment, including the specific route, to 

include any stops or layovers (such as for unloading and cleaning of tank cars) and all 

railroads that will be involved with the movement with the approximate distance of the 

movement. 

 The rationale for the request (why the repairs cannot be made at the current or nearest 

repair location). 

 Any restrictions the railroad or car owner believes should be applied to the movement. 

 The point of contact (name, address, telephone, e-mail address and fax number) where 

the subject equipment is located, so that an FRA inspector can schedule an inspection. 

 Name, title, address, telephone, e-mail address and fax number of the person requesting 

the OTM. 

 

How to Expedite:

In order to expedite the process, the OTM request may be faxed to FRA’s headquarters in 

Washington, DC, at (202) 493-6309, or if it is a Regional-Local OTM, the request can be faxed 

to the appropriate regional office as noted above. The fax cover sheet should be addressed to the 

attention of the Staff Director, Motive Power & Equipment Division, or the Regional 

Administrator, accordingly. However, the signed original request letter must in all cases be 

addressed to the Director of the Office of Safety Assurance and Compliance and mailed to the 

appropriate address, either headquarters or the appropriate regional office. 

Note: All OTMs that are to be made between regions, and any export movements, must be 

submitted to and processed by headquarters in Washington, DC. 

OTMs that come through headquarters will be handled by the headquarters staff. Headquarters 

will contact the appropriate region for an inspection of the equipment. The region will develop a 

report of findings, along with any recommendations regarding safety conditions or concerns. 

Headquarters will draft the final response letter and provide a copy of the letter to the relevant 

region prior to the movement taking place. 

“Regional-Local” OTM authority that is only within the boundaries of a single FRA Region can 

be approved by the regional management. The region granting the OTM must provide an e-mail 
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2 - 8 

and/or fax copy of the original request letter, along with a copy of the letter granting the 

authority to move the equipment (or denial), to the Director of the Office of Safety Assurance 

and Compliance, prior to the movement. The letter must use the same or similar format used by 

headquarters for OTMs, containing the following information: 

 The reporting mark/number and the type of equipment (e.g. locomotive, covered hopper 

car, passenger car), for which the relief is requested, along with the corresponding 

Federal regulation for the OTM. 

 The status of the equipment, to include all noncomplying components. State the cause of 

any damage (e.g., collision/sideswipe, grade crossing collision, derailment). Also, 

address all precautions required to ensure the safety of railroad personnel during the 

move, such as removal of sharp edges, loose or crushed components, addition of 

temporary safety appliances and/or caution tape, roped-off stairway, etc. 

 The point of origin and final destination of the equipment, including the specific route, to 

include any stops or layovers (such as for unloading and cleaning of tank cars) and all 

railroads that will be involved with the movement with the approximate distance of 

movement. 

 Any restrictions the railroad or car owner believes should be applied to the movement. 

 The FRA point of contact (name, address, telephone and fax number) for the requestor to 

call in case there is an incident or to notify when the OTM is completed. 

Regions must consult with headquarters for appropriate OTM restrictions if mechanical 

engineering issues are in question. 

 

Regular Complaint Investigations

Refer to the Complaint Investigations in Chapter 5 of the General Manual for detailed 

procedures.

Complaints are generally filed by railroad employees, labor organizations, or the general public. 

The complaint may be submitted by either formal letter, e-mail, telephonic, or verbal format. 

Complaints may be referred by other State or Federal agencies. The inspector assigned to a 

complaint investigation normally knows the identity of the complainant and the names of 

potentially helpful contacts. 

Attention: The complaint investigation must be conducted without revealing to anybody that a 

complaint is or was under investigation. An inspector may not, under any circumstances, 

reveal the identity of the complainant to anyone not employed by the FRA, unless: 

 The complainant authorizes such disclosure in writing; or 

 FRA refers the matter to the Attorney General (AG) for enforcement, discussion limited 

to persons within the AG’s office. See 49 U.S.C. 20109. 
Motive Power and Equipment Compliance Manual 

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The region will assign the complaint to an inspector, who will complete the investigation within 

60 days. If a complaint investigation cannot be completed in 60 days, the inspector will write a 

memorandum or e-mail to the regional office explaining the reasons for the delay. Each five 

days thereafter, until completion of the complaint, the inspector will submit a memorandum or email to the regional office explaining the status of the complaint. 

Complaint investigation must be thoroughly investigated the first time. Job pressures must not 

interfere with the investigation, even if it is thought that the investigation is taking an inordinate 

amount of time. 

Focused Enforcement Inspections

Focused enforcement entails concentrating enforcement efforts primarily on the types of 

violations most likely to cause an actual train accident or injury. FRA’s accident/injury database 

provides a wealth of information on what these leading causes of accidents and injuries are. The 

basic principle here is allocating our finite enforcement resources on those areas where 

improvements in compliance are most likely to produce maximum safety benefits. The principle 

is the same with regard to allocating inspection resources; as discussed in a separate document 

on inspections, we need to use available information on safety risk criteria to better guide our 

selection of inspection priorities. 

FRA inspectors shall utilize FRA’s accident, injury, and inspection data to gain better insight 

into the types of violations that are actually causing large numbers of accidents and injuries. 

While much of the information is already available to the field, FRA will distribute to the field 

data summaries showing the leading causes of train accidents and injuries by safety discipline, 

cause code, and regulatory section. The data will be industry-wide and broken down by railroad. 

With this information, inspectors will be better equipped to weigh the discretion criteria 

concerning the inherent seriousness of violations and the level of risk posed in specific 

circumstances. This is not to suggest that enforcement decisions are to become entirely driven 

by data. Direct observations and experience will always be necessary elements of these 

decisions. However, because the agency has adopted certain performance goals linked directly 

to reducing the rate of certain unsafe events, we need to make better use of the data we collect to 

help guide our achievement of those goals. 

In-depth accident analyses are conducted to determine if any laws, rules, or orders within FRA’s 

jurisdiction have been violated and what remedial action should be taken. In addition, inspectors 

must study accident trends in their inspection territory, especially those attributed to human 

factors and mechanical practices; to include inspections, tests, and repairs. Information is 

available for each railroad in the inspector’s territory and will be helpful in outlining inspection 

plans and setting safety priorities. Site-specific inspections should be performed on the basis of 

each inspector’s knowledge of enforcement areas requiring more attention to ensure safety. An 

inspector’s knowledge of each railroad within the inspection territory should determine the types 

of inspections which must be performed. For example, if a recent human factors-caused accident 

was related to an improper air brake inspection, concentrated inspections of the railroad’s air 

brake inspections should be conducted at various times throughout a 24-hour period, to include 
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weekends. Where inspectors are focusing on leading causes of accidents and injuries, their 

violation reports should summarize the factors underlying their decision. 

In the meantime, inspectors are encouraged to make use of data already at their disposal, 

including accident data, inspection data, and their own experience about the most important 

safety hazards. Inspectors should give this information great weight and strongly consider 

enforcement action whenever these especially unsafe conditions occur, with a goal of 

maximizing the safety return on enforcement efforts. While some enforcement actions will 

continue to be necessary on matters that are not likely to actually cause accidents or injuries but 

violate regulations that are important underpinnings of an effective regulatory program (e.g., 

recordkeeping), those matters that are serious safety concerns are more likely to be the prime 

candidates for enforcement actions. Reporting, recordkeeping, and inspection violations become 

more important to the extent they are widespread and/or bear directly on compliance with 

substantive requirements. 

Over time, this more careful focus on how enforcement discretion is exercised should 

significantly improve FRA’s utilization of limited resources regarding compliance oversight. On 

the other hand, as we refine the process, we may decide to adopt a “zero tolerance” (i.e., always 

enforce) policy for the most egregious and flagrant violations. The goal is not to achieve a 

particular volume of enforcement actions on the high or low side. The goal is a compliance 

program in which enforcement discretion is routinely exercised in a commonsense way to 

address important problems that more cooperative enforcement methods have not resolved. 

 

Sample Locomotive/Car Inspections

Inspectors should review the training CD that was disseminated to them prior to conducting the 

sample car inspection for detailed information and procedures. 

Sample car/locomotive inspections are performed as a courtesy to the manufacturers, to ensure 

that the equipment is built in accordance with all applicable Federal regulations and 

requirements. Car builders that desire to have the FRA review their equipment for compliance 

with safety appliance standards are to submit their safety appliance arrangement drawings, prints, 

etc., to the FRA Office of Safety Assurance and Compliance for review, at least 60 days prior to 

construction. All requests and drawings should be submitted to the following address: 

Director 

Office of Safety Assurance and Compliance 

1200 New Jersey Avenue, SE 

West Building, Third Floor, Mail Stop 25 

Washington, DC 20590 

FRA will review the documents submitted and advise the builder as to the status. The builder 

should then notify the Office of Safety Assurance and Compliance at least 30 days in advance of 

when the sample equipment will be ready for inspection. Once the request is received, 

headquarters will coordinate with the appropriate regional office as to the date and location of a 
Motive Power and Equipment Compliance Manual 

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scheduled sample car/locomotive inspection. The Regional Administrator will appoint an 

experienced inspector to conduct the inspection. 

If the location of the sample car/locomotive inspection is in Canada, the regional office shall 

coordinate the inspection activity with representatives from Transport Canada so that a joint 

inspection can be conducted. 

The individual assigned to perform the sample car/locomotive inspection shall review in advance 

the current MP&E Sample Car/Locomotive Inspection Procedure Guidelines, pertinent 

regulations covering the type of car or locomotive to be inspected, and (if possible) the current 

Association of American Railroads (AAR) Manual of Standards and Recommended Practices or 

the American Public Transit Association (APTA) Standards applicable to the car or locomotive 

to be inspected. Inspectors should have the necessary equipment to perform the inspection (i.e., 

appropriate regulations and standards, gauges, camera, ruler, measuring devices, and the 

checklist which is provided in appendix. 

The equipment inspected must strictly comply with the applicable sections of: 

49 CFR Part 215 Freight Car Safety Standards 

49 CFR Part 223 Safety Glazing Standards 

49 CFR Part 224 Reflectorization 

49 CFR Part 229 Locomotive Safety Standards 

49 CFR Part 231 Safety Appliance Standards 

49 CFR Part 232 Power Brake Systems 

49 CFR Part 238 Passenger Car Equipment Safety Standards 

49 CFR Part 239 Passenger Train Emergency Preparedness 

In addition to regulatory requirements, the equipment should be examined from a standpoint of 

overall operational safety. Conditions not covered by regulations should be addressed in the 

assessment of the equipment. Photograph and describe in detail any condition detrimental to 

safety, or that has the potential to become a detriment to safety. 

While performing the inspection of the brake system, it is important to examine the location of 

pertinent brake components which must be observed during the performance of required brake 

inspections by railroad inspectors. The brake must be designed so that a railroad inspector can 

observe from a safe position, either the piston travel, an accurate indicator which shows piston 

travel, or any other means by which the brake system is actuated. The design shall not require 

the railroad inspector to place himself or herself on, under, or between components of the 

equipment to observe the brake actuation or release during a required train air brake inspection. 

Unsafe and questionable conditions must be identified and reported to the car/locomotive 

manufacturer during the inspection.

FRA Form F6180.4, Special Inspection of Safety Appliance Equipment, will be completed for 

each type of equipment inspected. Normally a sample car inspection does not require an FRA 

F6180.96 report. A computerized version of the F6180.4 report, in WordPerfect format, has 

been developed for use. 
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Each block of the F6180.4 shall be completed. Enter “N/A” in spaces that do not apply. If an 

appliance deviates from the standards, enter the dimensions or description in the appropriate 

space on the front of the form. Any deviation from FRA regulations must be documented on the 

F6180.4 report and reported to the builder’s representative for corrective action. If necessary, a 

memorandum may be used to supplement the F6180.4. 

The Hand Brake entry should include the manufacturer and model number. 

The Handhold and Ladder Tread entries should show clear, usable length. 

The Power Brake block should show the type of brake applied, such as WABCO - ABDWXL, or 

NYAB - ABDW, or an ECP brake system. Additional information may be included describing 

the brake system (i.e., 12 -inch cylinder, empty-load sensing equipped, stand-alone or overlay 

ECP system, etc.). 

A minimum of six photographs must be supplied that clearly show the safety appliance 

arrangements and any noncomplying conditions, to include each corner of the car and both ends 

of the car. Also, any defect noted should have a photo to support it. 

The inspector should use the “sample car inspection checklist” when performing the sample car 

inspection and submit a copy of the check list with the F6180.4 report in the package to 

headquarters. The inspector should also try to obtain a copy of the golden shoe test report, along 

with any other brake test reports, slewing reports, etc., and include the copies in the package that 

will be forwarded to headquarters. 

At the conclusion of the inspection, the inspector should inform the car builder of the findings. 

However, the inspector is not to advise the builder that the “sample car” meets all Federal 

requirements. Headquarters will advise the builder and the region on the car’s status of 

compliance or noncompliance. The Office of Safety Assurance and Compliance will provide the 

car builder, in writing, the results of the sample car inspection. 

MP&E Safety Concern & Recommendation Report F6180.4A

During regular inspection of railroad rolling stock equipment, the inspector may or may not be 

sure compliance has been achieved when encountered by a potential safety concern or systemic 

safety condition. Conditions where compliance is in question and that warrant further 

investigation without removal of equipment from service should be reported by using this form. 

Answers to questions such as “Has previous relief been provided by waiver, sample car 

inspection, or other regulatory process?” when performing field inspections usually are not 

readily available. Inspectors are encouraged to complete this form by filling out any potential 

unsafe condition(s) that he/she believes there is no clear guidance on compliance. 

The inspector shall contact his/her MP&E specialist to determine if there may be a valid safety 

concern. The regional MP&E inspector and MP&E specialist will contact MP&E headquarters 
Motive Power and Equipment Compliance Manual 

2 – 13 

to discuss the safety concern. If warranted, headquarters will provide an FRA control number to 

identify the safety concern. 

Once the regional specialist and headquarters determine that the condition is a safety concern, a 

Form F6180.4A will be completed. The Form F6180.4A, MP&E Safety Concern & 

Recommendation Report, will be completed for each potentially unsafe condition for tracking of 

each reportable defect. This F6180.4A, MP&E Safety Concern and Recommendation Report, is 

located at the end of Chapter 2. 

Once a control number has been assigned, the Form F6180.4A report will be completed. Enter 

the information contained within the report; all blocks must be completed. Each field is 

expandable to assist the inspector in including additional information. 

Photographs of a safety concern along with other tools necessary to help determine the condition 

should be included by attaching text or photography to the report. 

Once the F6180.4A has been received at headquarters, the staff specialist will contact the 

appropriate parties to discuss the issue and make recommendations to bring the equipment into 

compliance or discuss other regulatory processes for resolution. In the event relief has been 

provided, a response will be sent to the MP&E specialist and the matter will be considered 

closed. 

F6180.4A reports submitted will be entered into the headquarters database, and will be placed on 

the FRA secure site to monitor progress of each reported incident. 
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 OMB No. 2130-0565 

FRA F 6180.4a (11/04) 

Public reporting burden for this information collection is estimated to average 60 minutes 

per response. This estimate includes the time for completing the inspection and filling-out 

this form. According to the paperwork Reduction Act of 1995, no persons are required to 

respond to a collection of information unless it displays a valid OMB control number. The 

valid OMB control number for this collection of information is 2130-0565. 

U.S. Department of Transportation 

Federal Railroad Administration MP&E SAFETY CONCERN & RECOMMENDATION REPORT

Inspector(s) Name: Inspector ID: Date: Region: FRA Control 

No.: 

 

Built Date: Type: (e.g. B, CH, AC, etc. use code from F6180.96 / RISPC 

table) 

 

Name of Builder and/or Owner: Location of Builder and/or Owner: (City & State) 

 

Initial: Number: 

Were Concern(s) Recorded On F6180.96: ☐ Yes 

☐ No 

If Yes, Indicate Inspector Initials Followed by 

Inspection Report No.(s): 

Approximate Number Of Units 

With 0 Reporting Marks: 

If Known, Approximate Number Of Units In Service With The Concern(s) Described Below: 

CFR Section And Text Reference: (Cite Complete CFR Section, TB, and Corresponding Text 

Description) 

Description Of Concern(s): 

Cite Any Safety Concerns, Known History Of Injuries/Fatalities/Derailments, etc. Associated With This 

Issue: (Names, Dates, Location, etc.) 

Inspector Recommendation(s): 
Motive Power and Equipment Compliance Manual 

2 – 15 

Site-Specific (Routine) Inspections

Refer to the General Manual, Chapter 3 for detailed information regarding regular inspection 

activities. 

MP&E inspectors are not required to announce their presence on railroad property, nor are they 

required to provide advance notice of an inspection, investigation, follow-up, or surveillance 

activity. However, advance notice may be necessary to ensure the availability of records, 

equipment, carrier representatives, and/or persons to be interviewed. 

Upon completion of an inspection, the inspectors shall confer with a railroad representative to 

advise them of any noncomplying conditions or practices discovered by the inspection. The 

inspector should cite the defective conditions and the applicable regulation that is in 

noncompliance. If time permits, a written report will be given to a railroad representative before 

the inspector leaves the railroad’s property. If the railroad representative is not present or the 

inspector does not have sufficient time to complete a written report, then one shall be completed 

during the next work period and delivered or forwarded to the railroad representative. 

When conducting an inspection at a remote location where no railroad representative is available, 

a railroad official shall be contacted at the completion of the inspection and advised of the 

results. 

The RISPC Program, F6180.96: Form F6180.96 inspection report preparation is mandatory 

for all inspections where civil penalty action (a violation report) is recommended. Federal 

regulations (Ref. 49 CFR § 209.405(a)) require railroads to submit Report of Remedial Action to 

FRA for all violations 30 days after the end of the calendar month in which notice of violation 

occurred. To complete the regulatory cycle, inspectors should complete the Remedial Action 

portion of the inspection report, as soon as the report (railroad copy), is received from the 

railroad. Inspectors are required to update all inspection reports containing violations as soon as 

possible. This helps ensure the integrity of FRA’s inspection report database and the regulatory 

requirements. 

All defective conditions must be listed on FRA Form 6180.96. Inspectors must not create a 

separate F6180.96 report for each violation taken during an inspection activity. The F6180.96 

report is designed so that the inspector can list all of the defects taken for an inspection activity 

and identify which defect is being recommended for civil penalty by checking the appropriate 

box. When the violation box is checked “Yes” on the F6180.96 inspection report line item, some 

of the information is automatically transferred from the F6180.96 inspection report to the FRA 

Form F6180.109 violation report. 

FRA Form F 6180.109: This report replaces all other MP&E violation reports previously used 

in connection with violation reporting of MP&E type violations, except for those associated with 

Parts 218 and 221. FRA Form F6180.109 is a component of the RISPC program and can be 

accessed from within RISPC or via a shortcut icon. FRA Form F6180.109 will be used for the 

following violations: 
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 Part 209 - Railroad Safety Enforcement Procedures 

 Part 210 - Railroad Noise Emission Compliance Regulations 

 Part 215 - Railroad Freight Car Safety Standards 

 Part 223 - Safety Glazing Standards-Locomotives, Passenger Cars and Cabooses 

 Part 224 - Reflectorization of Rail Freight Rolling Stock 

 Part 229 - Railroad Locomotive Safety Standards 

 Part 230 - Steam Locomotive Inspection and Maintenance Standards 

 Part 231 - Railroad Safety Appliance Standards 

 Part 232 - Brake System Safety Standards for Freight and Other Non-passenger Trains 

and Equipment; End-of-Train Devices 

 Part 238 - Passenger Equipment Safety Standards 

 Part 201 (40 CFR - Certain Noise Violations) 

 Statutory Violations – U.S.C. 49 Subtitle V Chapters 203 & 207 

Note: A narrative section is still required and must be inserted in Item 44 (Violation 

Narrative) of the form. In most cases, the narrative will require the use of attachments. 

It is recommended that in Item 44 (Violation Narrative) the word “Attachments” be 

included at the bottom of the page, followed by a Table of Contents page, then followed 

by all subsequent pages of attachments. 

FRA Form F6180.67: The Violation of Federal Railroad Safety Regulations form is used to 

submit violation reports in connection with 49 CFR Part 218 - Subpart C, Blue Signal Protection 

of Workers, and Part 221 - Rear End Marker Devices. FRA Form F6180.67 is also used for 

other operating practices violations. Detailed instructions similar to these are also embedded in 

the RISPC program. Refer to those instructions for completing FRA Form F6180.67. This form 

behaves in the same manner as FRA Form F6180.109 and resides within the RISPC program. 

Submission of Photographs as Evidence: Photographs provide strong evidence in support of a 

violation. If photographs are included in the violation, the inspector will attach (mount) each 

photograph to a piece of paper and explain what each photograph shows (be certain that the 

photo clearly depicts the defect and location of the defect(s) in question). If photographs are part 

of the evidence, both the original and second copy of each violation report must have mounted 

photographs when they are submitted to FRA’s Office of Chief Counsel. This is required so that 

when one copy is furnished to the respondent, the respondent will have the same evidence that 

the FRA has in its possession. Copies of digital photographs are acceptable, provided the 

inspector makes a statement in his/her violation report indicating the digital photographs have 

not been altered in any way. Photographs that have been altered in any way must not be 

included as violation evidence. 

Note: Refer to MP&E Technical Bulletin MP&E 05-01 for Violation Report Form F 6180.109, 

Item and Field description and required information 

 

Statements of Witness or Reports of Interview: Unless a violation is substantiated by an 

inspector’s personal knowledge or by records the FRA requires railroads to maintain, the 

violation report should be accompanied by statements of witness reports obtained from railroad 
Motive Power and Equipment Compliance Manual 

2 – 17 

employees, railroad officials, or other persons who know the circumstances surrounding the 

noncomplying act or condition. If a statement is the only proof of noncompliance, the use of a 

witness statement is required. 

Copies of Railroads’ Records: When applicable, the violation report must be accompanied by 

legible copies of the railroad’s applicable records, containing information that will provide the 

FRA Office of Chief Counsel with substantiating documentation and a clear understanding of the 

violation of Federal safety regulations. 

This information may be submitted in the form of duplicated copies of the railroad’s records or 

through comprehensive, word-for-word extracts taken from the railroad’s records. 

Operation Life Saver Presentations

Refer to the General Manual, Chapter 6, for certification requirements and presentation 

guidelines. 

FRA’s Jurisdiction Over Tourist and Excursion Railroads 

Please refer to “Safety Jurisdiction over Tourist Railroads” section on Page 30 and 31 of the 

General Manual for additional information. 

As with many agencies of the federal government, the FRA does not extend the “full reach” of 

most of its regulations as far as the statute permits for either resource or policy reasons. To 

identify the agency’s current policy regarding the scope of regulatory enforcement for certain 

types of railroads, FRA developed a set of guidelines. These guidelines are meant to clarify the 

extent of and proper application for the jurisdiction that the agency chooses to exercise. The 

purpose for this chapter is to provide enforcement guidance for tourist and excursion railroads. 

Guidance:

FRA will exercise jurisdiction over all tourist operations, whether or not they operate over the 

general railroad system, except those that are (1) less than 24 inches in gage and/or (2) insular. 

The FRA considers an operation insular if it is limited to a separate enclave in such a way that 

there is no reasonable expectation that the safety of any member of the public, except for a 

business guest, a licensee of a tourist operation or an affiliated entity, or a trespasser, would be 

affected by the operation. Therefore, an operation will not be considered insular if one or more 

of the following exists on its line: 

• A public highway-rail crossing that is in use. 

• An at-grade rail crossing that is in use. 

• A bridge over a public road or waters used for commercial navigation; or 

• A common corridor with a railroad, i.e., its operations are within 30 feet of those of any 

railroad. 

Thus, the mere fact that a tourist operation is not connected to the general railroad system would 

not make it insular under these criteria. While these criteria will tend to sort out the insular 
Federal Railroad Administration 

2 - 18 

theme parks and museums, there will still be a need to do case-by-case analysis in some close 

situations. 

Regulation:

Tourist railroads are not required to comply with the requirements of either Title 49 CFR Parts 

238 or 239. However, tourist railroads that operate on the general system must comply with all 

statutes and all regulations, unless and until any appropriate waiver has been applied for and 

granted. Of course, FRA generally lacks authority to waiver statutory requirements. 

Some tourist railroads are neither insular nor part of the general system (i.e. stand-alone lines 

with no freight traffic.). In these instances only the following statutes apply: 

• 49 USC §§ 20102, 20301, 20302, 20303, 20502-20505, 20701, 20902, 21302, 21304 

(formerly 45 USC §§ 1, 2, 4, 9, 11, 13, of the Safety Appliance Act and 45 USC 22 et 

seq. of the Locomotive Inspection Act); and 

• Federal signal inspection laws, 49 USC §§ 20102, 20502-20505, 20902, 21302, 21304 

However, FRA’s emergency order authority permits the agency to address a true safety 

emergency arising from specific conditions. Thus, even “off-the-system” tourist railroads should 

understand that FRA has the jurisdiction to inspect their operations, and to take emergency 

action if those operations pose an imminent hazard of death or injury. 

The chart below provides a general guidance in deciding the scope of compliance. 
Motive Power and Equipment Compliance Manual 

2 – 19 
Federal Railroad Administration 

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Source Codes

The following source codes are the only source codes to be used by MP&E inspectors. When 

applying the appropriate source code on inspection reports, the inspectors should remember that 

FRA must, at all times, focus on the quality of inspection efforts. For many years, our estimates 

have indicated that we have the ability to actively monitor about two-tenths of one percent (i.e. 

0.2%) of railroad operations. Current data shows a similar relationship between railroad 

operations and FRA inspection capacity. 

Please note that according to Technical Bulletin G-07-03, the selectable Source Codes have been 

reduced in the RISPC. Five codes have been eliminated and will generate error messages in the 

inspection reports if they are used. Those codes are: 

F – Federal Assistance Investigation 

G – Other 

K – Inspection from Train 

W – Focused Inspection 

Y – Inbound Extended Haul Trains 

In place of codes F, G and W, please use Source Code D, Special Investigation. Source Code D 

requires that the File Number box be filled in. The previously used Source Code W for Focused 

Inspections or for Audits will now need to use Source Code D along with unique File Number. 

The File Number should be descriptive and mean something to you. The File Number box has 

18 characters to work with. 

The most recent revision of the Source Codes took place on February 29, 2008. It should now be 

error-free. If Source Code W is used after February 29, 2008, you would get an error message. 

If the report does not recommend a violation, then simply change the Source Code D to add a 

File Number, and then save the report. If the report contains a recommended violation and the 

report is locked, please call ActioNet at 703-204-0090 x 248, and ask for assistance in getting 

that changed without having to delete the violation report. 
Motive Power and Equipment Compliance Manual 

2 – 21 

MP&E Source Codes 

A: Regular inspection – A periodic inspection activity conducted by Federal and State 

railroad safety inspectors, in accordance with established procedures, to determine 

railroad, shipper, consignee, contractor, and manufacturing facility compliance with 

Federal statutes, rules, regulations, orders and standards within the jurisdiction of FRA. 

B: Complaint Investigation – Any inspection initiated for the purpose of performing a 

complaint investigation. A complaint file number must be assigned and indicated on the 

inspection report when this code is used. 

C: Accident Investigation – Any inspection resulting from an accident/incident 

investigation. An accident file number must be assigned and indicated on the inspection 

report when this code is used. 

D: Special Inspections or Investigations – Inspections initiated for a specific reason or 

purpose not otherwise identified. A file number must be assigned and indicated on the 

inspection report when this code is used. 

E: Waiver Investigation – Inspections resulting from investigating requests for temporary 

relief from Federal regulations. A waiver investigation file number must be assigned and 

indicated on the inspection report when this code is used. 

F: ECP Brake-Equipped Trains (MP&E) – Inspectors must complete a separate inspection 

report using Source Code G, along with all related inspection activity associated with the 

ECP brake-equipped trains (e.g., Parts 215, 231, 232, etc.). Source Code G must also be 

used when inspection activities, such as Parts 218, 223, 229, etc., involve ECP brakeequipped trains and equipment. 

H: Nuclear Route Shipment – Inspections of nuclear routes or shipments as specified in the 

Safety Compliance Oversight Program (SCOP) Plan. 

R: Re-inspection – Inspection activity carried out to examine, monitor, or further develop 

previously conducted work. Inspectors must use good judgment when deciding the 

appropriate interval for the re-inspection, taking into consideration factors such as the 

inherent seriousness of the noncompliance and the railroad’s general level of current 

compliance as revealed by the original inspection as a whole. Signal and Train Control 

inspectors and Track inspectors must also be governed by discipline specific guidelines. 

The File Number field must contain the Inspector ID and previous Inspection Report 

Number. 

V: Inspection of or at Manufacturer’s Facility – Inspection activities for the purpose of 

conducting a sample car or sample locomotive inspection at the manufacturing facility, in 

accordance with established procedures, to ensure that the equipment is built in 

accordance with all applicable Federal statues, regulations, and requirements. 
Federal Railroad Administration 

2 - 22 

Z: Outbound Extended Haul Trains – Any inspection activity conducted on an extended haul 

train at the designated outbound inspection point by Federal and State railroad safety 

inspectors, in accordance with established procedures, to determine railroad and/or 

contractor’s compliance with Federal regulations as prescribed in 49 CFR 232.213(a)(2) 

through (a)(5). This code shall also be used for any inspection activity at locations where 

cars are added en route to an extended haul train. 
Motive Power and Equipment Compliance Manual 

2 – 23 

Activity Codes

The activity codes to be used by MP&E inspectors can be found in the “Multi-discipline Code 

Table of Definitions shown at the end of this section. 

When applying the appropriate activity code on inspection reports, inspectors should remember 

that the quality of the inspections and how the information regarding the inspections is captured 

is paramount to the inspection process. The information obtained from FRA’s inspections are 

used to support rulemakings, waiver decisions, deployment of inspections, trend analysis, 

research and development projects, accident/incident analyses, and the overall condition of our 

Nation’s railroads. In order to ensure that the data used for compiling statistics or for any 

analysis work is precise and consistent, inspectors need to adhere to the following guidelines 

when reporting the results of any inspections. 

When conducting inspections for compliance with the following parts, inspectors are required to 

inspect the entire car/locomotive/train in order to count that activity as a unit for the unit count of 

the inspection report: 

 Part 215 Freight Cars 

 Part 224 Reflectorization 

 Part 229 Locomotives 

 Part 230 Steam Locomotives 

 Part 231 Safety Appliances 

 Part 232 Power Brakes 

 Part 238 Passenger Car Equipment 

However, there will be times when only one side of the car, locomotive, or train can be 

inspected. This constitutes a partial inspection, which is the exception, not the normal inspection 

practice. If an inspector is unable to inspect the entire car, locomotive, or train, the inspector 

must describe why only a partial inspection was performed in the line item description field 

(narrative) and the letter P must be entered in the class box of the line item. When the letter P is 

placed in the class box, every activity code used on the report will be captured as a partial 

inspection. Therefore, if the inspector performs an entire inspection of the locomotives on a 

train, but only inspects one side of the train (Parts 215, 224, 231, or 232), two inspection reports 

need to be made; one report for activity that received a complete inspection and one report for all 

activity that only received a partial inspection. Two inspection reports should be generated when 

activity codes for Part 218, Blue Signal Protection, Part 221, Rear Markers, and Part 223, 

Glazing, are used in conjunction with partial inspections. 
Federal Railroad Administration 

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Multi-discipline Code Table of Definitions 

Revised January 7, 2012 

Activity Discipline Definition Comments 

174A H, M General Requirements – The purpose of this inspection is to 

determine compliance with §§174.3, 174.5, 174.9, 174.14, 

174.16 and 174.50. Record one unit for the inspection of 

each car transporting hazardous materials. 

174B H, O General Operating Requirements – The purpose of this 

inspection is to review a train crew’s documentation for each 

railcar containing hazardous material, including any changes 

in placement of the car. The inspection should include 

determining compliance with the basic hazardous materials 

shipping paper descriptions as required in §174.26. Record 

one unit for each train consist inspected, and one subunit for 

each inspection of the basic shipping paper description of 

each car containing hazardous materials. 

Note 1: Inspectors must use activity code TPLH to record 

inspections associated with train placement requirements. 

Note 2: Inspectors must use this code instead of code 172C 

when inspecting shipping papers specific to a particular 

train. 

209 ALL Remedial Action – The purpose of this inspection is to report 

a railroad that has not complied with a requirement to provide 

a remedial action as noted in a previous inspection report. 

Record one unit for each remedial action not in compliance. 

(See General Manual for additional guidance).

215D H, O, S, T Freight Car Mechanical Inspection – The purpose of this 

inspection is for any inspector other than an MPE inspector

to determine compliance with § 215, including Appendix D. 

The inspection includes those performed by an FRA inspector 

or when an FRA inspector observes railroad employees 

performing this inspection. MPE inspectors should reference 

activity code 215. Record one unit for each freight car 

inspected or observed inspected for compliance with §215. 

For articulated cars, count each platform as one unit. 

 

Note 1: HM and OP inspectors should use this activity code 

HM for ALL of their Part 215 inspections. 

Note 2: Properly stenciled Maintenance-of-way equipment is 

exempt from Part 215.305(b).
Motive Power and Equipment Compliance Manual 

2 – 25 

Activity Discipline Definition Comments 

217E ALL Emergency Order – The purpose of this inspection is to 

determine compliance with a current Emergency Order. 

Record each unit and subunit as directed by the unique 

instructions issued by FRA HQ regarding each specific 

Emergency Order. Inspectors must thoroughly explain the 

inspection in the inspection report’s narrative. 
Federal Railroad Administration 

2 - 26 

Activity Discipline Definition Comments 

217O ALL Other Operations Observations - The purpose of this 

inspection is to observe railroad employees of any craft 

performing duties regarding railroad operating rules (ROR), 

and railroad safety rules(RSR). It will include all related 

RORs, RSRs, railroad bulletins, and any written railroad 

policy not otherwise covered in Federal regulations. 

Noncompliance will be recorded as a Non-FRA defect under 

this activity code. Record one unit for an entire yard or 

equivalent facility monitored, and one subunit for each 

crewmember, yardmaster, contractor, track employee, 

mechanical employee, signal maintainer, etc, that the 

inspector continually observed a sufficient amount of time to 

determine compliance or noncompliance. 

Note: Unlike noncompliance with Federal regulations, it is 

FRA policy that inspectors provide information recorded 

under this activity code regarding noncompliance of an 

ROR/RSR without identifying the noncompliant employee 

by name in the Federal inspection report. See the General 

Manual for a further explanation. 

Example 1: An FRA Track Inspector observes a 20 person 

section gang working for approximately 45 minutes when the 

inspector observes a track employee sitting on the rail. The 

FRA inspector intervenes by addressing the employee’s 

noncompliance with an RSR, and then discusses the 

noncompliance with the employee’s supervisor. The 

inspection report will include the recording of one occurrence 

of a Non-FRA defect for a track employee’s failure to comply 

with the specific RSR that prohibits employees from sitting 

on a rail. The inspector will record the inspection as one unit 

and 20 subunits 

Example 2: An FRA MPE Inspector observes four persons 

working on a railroad car with proper Blue Signal protection 

for approximately 10 minutes when the inspector observes 

one of the workers perform a task while not wearing the 

required protective equipment. The FRA inspector intervenes 

by addressing the employee’s noncompliance with a RSR by 

discussing it with the employee’s supervisor. The inspection 

report will include the recording of a Non-FRA defect for a 

car shop employee’s failure to comply with the specific RSR 

that prohibits performing the task without the proper 

protective equipment. The inspector will record the 

inspection as one unit and four subunits. 
Motive Power and Equipment Compliance Manual 

2 – 27 

Activity Discipline Definition Comments 

218C O,S,T Camp Car Protection - The purpose of this inspection is to 

determine compliance with camp car protection. Record one 

unit for each track inspected that requires camp car protection. 

218M M, O Blue Signal Protection on Main or Other than Main Track 

- The purpose of this inspection is to determine if the 

protection provided railroad employees requiring Blue Signal 

protection in accordance with §§ 218.25, 218.27, and 218.30. 

Record one unit for each track that requires Blue Signal 

protection. If the track requiring Blue Signal protection has 

more than one train or cut of cars requiring protection record 

one unit for the entire track. 

Regarding inspecting compliance with Blue Signal 

regulations involving a remotely controlled switch. Record 

one unit for all associated recordkeeping requirements at that 

location, and one subunit for each track associated with those 

records. 

Note 1: Except for stub tracks, both ends of the track must be 

inspected for compliance with the Blue Signal regulations. 

Note 2: There is a drop-down FRA observation code 

inspectors may use in lieu of writing a comment when there 

are not any exceptions noted. 
Federal Railroad Administration 

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Activity Discipline Definition Comments 

218O ALL Part 218 Subpart F – The purpose of this inspection is to 

determine a railroad’s compliance with Part 218 Subpart F, 

including the requirement for a railroad to have complying 

railroad operating rules as indicated in the regulation. Record 

one unit for each day, or partial day, spent reviewing relevant 

railroad rules or for each yard or equivalent facility 

monitored. Record one subunit for each crewmember, 

yardmaster, contractor, track employee, mechanical 

employee, signal maintainer, etc, that the inspector 

continually observed a sufficient amount of time to determine 

compliance or noncompliance. 

Note: It is FRA policy that inspectors provide information 

regarding incidents recorded under this activity code as 

noncompliance of a Federal regulation. It will include 

identifying the noncompliant individual by name in the 

inspection report. See the General Manual for a further 

explanation. 

Example 1: An FRA Track Inspector observes a 12 person 

section gang working for approximately 45 minutes when the 

inspector observes a track employee throwing a switch with 

equipment in the foul of the switch. The FRA inspector 

intervenes by addressing the employee’s noncompliance with 

§218 Subpart F, and then discusses the noncompliance with 

the employee’s supervisor. The inspection report will include 

the recording of the noncompliance for the track employee’s 

failure to comply with Part 218 Subpart F, and the name of 

the employee in noncompliance. The inspector will record 

the inspection as one unit and 12 subunits. 

Example 2: An FRA MPE Inspector observes six persons 

switching railcars in a car shop for approximately 10 minutes 

when the inspector observes one of the workers fail to 

properly protect a shoving movement. The FRA inspector 

intervenes by addressing the employee’s noncompliance with 

§218 Subpart F, and then discusses the noncompliance with 

the employee’s supervisor. The inspection report will include 

the recording of the noncompliance for the car shop 

employee’s failure to comply with the Part 218 Subpart F, and 

the name of the employee in noncompliance. The inspector 

will record the inspection as one unit and six subunits. 

Example 3: An inspector reviews the railroad rules to 

determine if they are in compliance with the requirements 

setforth regarding railroad equipment in the foul and 

operating switches. The inspection report will include the 

recording of one unit for this inspection and will also 

reference the precise railroad rule(s), or lack thereof, in the 

inspection report’s narrative. 
Motive Power and Equipment Compliance Manual 

2 – 29 

Activity Discipline Definition Comments 

218S M, O Blue Signal Protection Locomotive or Car Shops - The 

purpose of this inspection is to determine compliance with 

regulations requiring Blue Signal protection in a locomotive 

servicing track area, a car shop repair track area, or a track 

that has been designated as a repair track or expedite track. 

Record one unit for each area inspected. 

If § 218.29(c), Alternative methods of protection, applied in a 

car shop repair track area or a locomotive servicing track area, 

one unit is recorded for the entire area, regardless of the 

number of tracks in the area or the number of cars or 

locomotives on those tracks. 

Note 1: Except for stub tracks, both ends of the track, or each 

entrance to the area must be inspected for compliance with the 

regulation. Workers must be on, under, or between 

equipment, inspecting, testing repairing, or servicing before 

recording a unit for this activity. 

Note 2: There is a drop-down FRA observation code 

inspectors may use in lieu of writing a comment when there 

are not any exceptions noted. 

221 M, O Rear End Markers – The purpose of this inspection is to 

monitor compliance with Part 221. This activity code should 

not be used when inspecting an End of Train (EOT) device 

under Part 232. Record one unit for each train, locomotive 

(including DPU’s) or caboose inspected for compliance. 

The inspection of each rear end marking device in rooms or 

locations where rear end marking devices are stored and/or 

recharged and maintained is one unit. Each rear end marker 

ID must be recorded in the line item along with the 

appropriate observation. Individual marking devices that are 

not attached to trains or in storage areas not subject to service 

are not recorded as a unit. 

Note: There is a drop-down FRA observation code inspectors 

may use in lieu of writing a comment when there are not any 

exceptions noted. 
Federal Railroad Administration 

2 - 30 

Activity Discipline Definition Comments 

227N IH 227N - Occupational Noise Exposure - The purpose of this 

inspection is to determine compliance with Part 227 regarding 

occupational noise exposure in the locomotive cab. It will 

include audiometric test records, employee noise exposure 

monitoring plan and monitoring records, cab noise monitoring 

records, postings of monitoring results, training plans and 

records, or interviewing persons regarding noise exposure. 

Record one unit for each day or partial day of an inspection 

and one subunit for each Part 227 record reviewed. 

Note: This activity may only be claimed when accompanied 

by a member of the Industrial Hygiene staff. 

228 O, S Hours of Service Records Inspection – The purpose of this 

inspection is to determine if Hours of Service (HOS) records 

are in compliance with Part 228. Record one unit for each 

day or partial day of inspection, and one subunit for each 

HOS record reviewed. This activity code includes any 

examination of HOS logs, HOS report forms, HOS 

documents, interviewing employees regarding HOS, and any 

other HOS records review activity. This activity code is not 

used to document an employee exceeding the HOS. 

Note: Reports taking exception to an employee exceeding 

the hours of service should not be recorded under this activity 

code, please reference the proper activity code associated with 

the employee’s type of work or discipline. Example: Activity 

Code 228P, 211, or HSL. 

228C O,S Construction of Employee Sleeping Quarters – The 

purpose of this inspection is to determine compliance with 

Part 228 Subpart C. Record one unit for each day, or partial 

day, spent reviewing relevant facilities regarding Part 228 

Subpart C. 

229X H, O Locomotive Inspection in Operations – The purpose of this 

inspection is for any inspector, other than an MP&E 

inspector, to determine a railroad’s compliance with Part 

229. Record one unit for any locomotive inspected. The 

inspection may include, but is not limited to, the locomotive 

daily inspection, any passageway tripping hazards, cab 

sanitation, cab lighting, speed indicator check, etc. 
Motive Power and Equipment Compliance Manual 

2 – 31 

Activity Discipline Definition Comments 

232E M, O End of Train Device – The purpose of this inspection is to 

inspect an End of Train (EOT) device for compliance of §232. 

The inspection must include verifying that the information on 

the calibration sticker is legible, and that it contains the date, 

name of person, and location of the last calibration. This 

activity also includes comparing the quantitative values 

between the front and rear unit, and the ability of the rear unit 

to effect an emergency application in response to an 

emergency application initiated from the front unit. Record 

one unit for each EOT inspected or observed for compliance. 

Note: This activity code will be used when citing defects on 

the Head End Device (HED) associated with the End of Train 

device (EOT). 

232O H, O, S, T Freight Train Brake Test Observation – The purpose of 

this inspection is for any inspector, other than an MP&E 

inspector, to determine compliance with Part 232 not covered 

in activity code 232E or 232X. It includes any airbrake test 

required by Part 232. Airbrake test inspections should 

include in the narrative of the inspection report if the 

inspector was observing or accompanying a railroad 

employee or contractor employee performing the airbrake 

test. Record one unit for each observation or inspection, and 

one subunit for each railcar involved. 
Federal Railroad Administration 

2 - 32 

Activity Discipline Definition Comments 

232X M, O Securement of Locomotive and Cars – The purpose of this 

inspection is to determine if railroad equipment is in 

compliance with §232.103 (n). Record units as follows: 

1. Record one unit for an inspection of unattended 

equipment that consists of a single locomotive or 

locomotive consist, either attached to cars or not. This 

inspection includes determining compliance with the 

requirements for throttle position, status of the reverse 

lever, position of the generator field switch, status of 

the independent brakes, position of the isolation 

switch, handbrake, and position of the automatic brake 

valve. 

2. Record one unit for an inspection of unattended 

equipment NOT attached to locomotives that are 

required to be secured under this regulation. This unit 

includes inspections for bottled air. . 

Note 1: If a train is separated to avoid blocking any type of 

crossing it should have each section of the equipment 

recorded as a separate unit. 

 

Note 2: The inspection report that records a defect or 

recommended violation indentified should clearly state the 

number of handbrakes found to be applied, the number of 

handbrakes required to be applied, and the current operating 

rule in place that indicates the precise number of handbrakes 

required to be applied. 

Note 3: This inspection also includes an inspector reviewing 

railroad rules for compliance of this part. 

Example: If 30 unattended railcars are found on a track that 

is required to have seven hand brakes applied but the 

inspection reveals that only has one handbrake is applied, it 

will be recorded as one unit with one occurrence for the 

failure to have the other six handbrakes applied. 

238O H,O, S, T Passenger Equipment Inspection (Partial) – The purpose 

of this inspection is for any inspector, other than an MP&E 

inspector, to determine compliance with Part 238 that is not 

covered in activity codes 232X or 238T. Record one unit for 

each inspection and a subunit for each passenger car 

inspected. 
Motive Power and Equipment Compliance Manual 

2 – 33 

Activity Discipline Definition Comments 

238T M, O Passenger Train Brake Test Observation – The purpose of 

this inspection is to document an observation of a passenger 

train airbrake test, excluding tourist equipment. Record one 

unit for each entire brake test observed for compliance with 

§238, and one subunit for each railroad record associated with 

the Class I airbrake test. 

Note: There is a drop-down FRA observation code inspectors 

may use in lieu of writing a comment when there are not any 

exceptions noted. 

238X M, O Passenger Equipment Securement – The purpose of this 

inspection is to determine if passenger or commuter 

equipment is properly secured (excluding tourist equipment). 

Record one unit for each train, whether or not a locomotive is 

attached. 

BWS S,T Bridge Worker Safety – An inspection concerning Part 214 

Subpart B, Bridge Worker Safety Standards. Record one unit 

for each bridge gang or work group, and one subunit for each 

member of the gang or work group. 

New 

activity 

code 

FC H, M Inspection of Freight Containers, General Handling and 

Loading Requirements – The purpose of the inspection 

includes inspecting the railcar for markings, placards, 

structural integrity, and securement. Record one unit for each 

exterior inspection of a container, and one subunit for each 

comprehensive inspection of a package. In addition to the 

above inspection criteria, a comprehensive inspection 

includes the inspection of the interior of the container for 

blocking & bracing and loading segregation requirements. 

This activity code may only be used when assessing 

compliance with §§ 174.55, 174.61, 174.81, 177.834. 

Note 1: Use BP codes to record intermodal tank inspections.
Federal Railroad Administration 

2 - 34 

Activity Discipline Definition Comments 

NOIR ALL Noise Test Records – The purpose of this inspection is to 

document a review of a locomotive’s noise testing session, or 

a locomotive’s noise testing record. Record one unit for each 

locomotive’s noise testing session monitored and/or all noise 

testing records associated with the locomotive tested. 

 

Example 1: A short line railroad has three records on file 

documenting a locomotive horn test performed on locomotive 

SP 1234. Record one unit for the examination of all three 

records. 

Example 2: A short line railroad has three records on file 

documenting a locomotive horn test performed on locomotive 

SP 1234, and two records on SP 2345. Record two units for 

the inspection of the noise testing records for two 

locomotives. 

Example 3: An inspector monitors three noise testing 

sessions on SP 4567, and then reviews three noise testing 

records regarding that same locomotive. Record one unit for 

the locomotive and testing records involved. 

Note 1: This activity code should only be used by inspectors 

who have been trained to inspect locomotive horn testing 

records. 

Note 2: This activity code should not be used with Part 227 

Occupational Noise Exposure inspections, (activity code 

227N), or when performing a noise test (activity code NOIS). 

 

New 

activity 

code 

NOIS ALL Noise Tests – The purpose of this inspection is to perform a 

noise test in accordance with Federal regulations. This 

activity code should only be used by inspectors who have 

attended the FRA training course regarding the equipment 

used to conduct these inspections. Record one unit for each 

day or partial day of an inspection. 

 

This activity code should not be used with Part 227 

Occupational Noise Exposure inspections, (activity code 

227N), or when reviewing noise records (activity code 

NOIR). 
Motive Power and Equipment Compliance Manual 

2 – 35 

Activity Discipline Definition Comments 

RADX H, O, T Radar Speed Monitoring – The purpose of this inspection is 

to monitor and/or accurately validate the speed of trains and 

railroad equipment for compliance with Federal regulations 

and/or railroad operating rules. Record one unit for each 

speed monitoring session and one subunit for each 

locomotive, train, or railroad equipment on the rail monitored. 

Non-compliance with railroad operating rules should be 

recorded under activity code 217O. 

Note 1: When entering this code, the inspector must indicate 

the initials and number of the lead locomotive, or a 

locomotive within the consist, in the Train # / Site Field. This 

Field permits the entry of 15 characters. Each train or piece 

of equipment monitored will require a new line item. 

Note 2: FRA and participating state employees must not 

perform radar monitoring sessions unless they received a 

certificate of qualification from an FRA employee who holds 

a current certificate as a stationary radar trainer. See Chapter 

3 of the General Manual for a complete discussion of FRA 

policy. 

Revised 2-

26/2011 

RMM T, S Roadway Maintenance Machine & Hi-Rail – The purpose 

of this inspection is to document an observation or inspection 

concerning § 214 Subpart D, On-Track Roadway 

Maintenance Machines and Hi-Rail Vehicles. Record one 

unit for each Roadway Maintenance Machine or Hi-Rail 

Vehicle inspected. 

Example: If a large scale tie unit consisting of 20 roadway 

maintenance machines and one Hi-Rail vehicle is operating 

on the tracks, and only five of those machines are inspected, 

then record five units. 

Note: If a machine operator fails to comply with railroad 

rules not covered by Part 214 or any Federal regulation the 

inspector must note the non-compliance by recording it using 

a Non-FRA defect under activity code 217O, as provided in 

the guidelines of that activity code. 
Federal Railroad Administration 

2 - 36 

Activity Discipline Definition Comments 

RULE ALL Rulebook Review - The purpose of this inspection is to 

record an inspector’s review or formal discussion with a 

railroad manager, regarding railroad rules that will determine 

if they accurately correlate with current FRA regulations. 

Record one unit for each day, or partial day, spent reviewing a 

railroad rule(s) for compliance with Federal regulations. 

Record a subunit for each CFR section involved. Only 

comments should be recorded under this activity code. Any 

defects should be recorded under the proper corresponding 

activity code. 

Note: Inspections regarding reviewing railroad rules to 

ensure compliance regarding §232.103 (n) and Part 218 

Subpart F should not be recorded under this activity code. 

Inspectors should reference activity code 232X and 218O 

respectively for those railroad rule inspections. 

Example 1: An inspection of NEBR railroad’s rulebook 

determined that railroad rules regarding signal systems (Part 

234 and Part 236) comply with Federal regulations. Record 

one unit and two subunits. 

Example 2: An inspection that included discussions with 

railroad managers regarding NEBR railroad’s rulebook and 

bulletins determined that the railroad’s rules regarding Part 

217 and Part 220 Subpart C, correlated with FRA regulations. 

Record one unit and two subunits. 
Motive Power and Equipment Compliance Manual 

2 – 37 

Activity Discipline Definition Comments 

RWP O, S, T Roadway Worker Protection – The purpose of this 

inspection is to determine compliance with Part 214 Subpart 

C, Roadway Worker Protection (RWP). Record one unit for 

an individual worker or group of employees (with a roadway 

worker in charge) at a specific location. This will include 

attending a job briefing with a group of RWP employees. 

Record each train required to provide an audible warning 

signal as a separate unit, and each employee requiring RWP 

as a subunit. 

Note: When performing multi-point inspection work with the 

same employee (or group of employees), record only one unit 

for determining compliance, and one subunit for each 

employee of the workgroup per day. 

Example 1: When observing or inspecting a large production 

crew, record a separate unit for each different location where 

an employee (or group of employees) is monitored for 

compliance. E.g. large projects may have multiple teams or 

workgroups at various locations along the right of way, record 

each worker, team or workgroup at each different location as 

a separate unit. 

Example 2: You observe an RWP crew consisting of one

employee-in-charge and 20 track employees together at a 

single location. Record one unit for the location and 21

subunits for the entire RWP work group. 

TC H, M Tank Car Inspection – The purpose of this inspection 

includes inspecting for markings, placards, and structural 

integrity. Record one unit for each ground level inspection 

that did not include a top level inspection. Record one 

subunit for each comprehensive inspection of a tank car. In 

addition to the above inspection criteria, a comprehensive 

inspection includes a ground level inspection of both sides

and a top level inspection as well. This activity code may 

only be used when assessing compliance with 

§§172.302(a)(1), 172.304, 172.502(a)(1)(i), 172.516(c)(2) and 

(6), 173.31, 174.50, 179, & 180. 

TPLH H, M, O In-Train Placement of Placarded Rail Cars, Transport 

Vehicles, and Freight Containers - The purpose of this 

activity is to determine compliance with positioning in-train 

of placarded cars, §§174.84 and 174.85. Record one unit for 

each train inspected. 
 

Chapter 3

Enforcement Actions

General

An MP&E inspector is not required to initiate formal enforcement proceedings each time a 

noncomplying condition is discovered. To achieve compliance, the inspector has a choice of the 

following actions: 

 Exception. This means documenting the noncomplying condition on the proper form 

and requiring only that the condition be corrected before using the equipment. 

 Violation. Used in conjunction with the requirements of an exception, a monetary 

penalty violation can be issued against the railroad. 

 Special Notice for Repairs. Used in conjunction with the requirements of issuing a 

violation, equipment not in compliance with 49 CFR parts 215, 229, 230, or 238 can be 

removed from service until it is in compliance. (See 49 CFR part 216.) 

 Individual Liability. Action can be taken against individuals in conjunction with the 

requirements of an exception and with or without issuing a violation or special notice for 

repairs against the railroad. This topic is discussed extensively later in this manual.

Determining When and What Enforcement Action is Necessary

Please read the General Manual both Chapter 3 - Inspections and Civil Penalty 

Recommendations and the memorandum - Improvements in Civil Penalty 

Enforcement Memo – Dated June 18, 2009 in the General Technical Bulletins and 

Other Guidance Documents for guidance. 
4 - 1 

Chapter 4 

Railroad Freight Car Safety Standards, Part 215 

Introduction

In accordance with the provisions of the Federal Railroad Safety Act of 1970, FRA issued 

Freight Car Safety Standards (49 CFR Part 215). The standards became effective on January 1, 

1974. Since 1974, there have been several amendments to Part 215. The railroad industry is 

constantly changing and FRA recognizes additional amendments will be needed to stay current 

with the changes. Advances in new technology, high-speed rail, the increasing number of 

articulated cars in service, new concepts in freight car construction, and the changing railroad 

environment will lead to changes to the Federal regulations. On the following pages, you will 

find interpretive guidance related to the freight car safety standards—as established by the 

agency—that will aid the inspector in the performance of freight car safety standards inspections. 

For convenience the guidance is organized in numerical order by section. 

 

In addition to Federal regulations, inspectors should be familiar with the Association of 

American Railroads (AAR) Interchange Rules and the AAR Manual of Standards and 

Recommended Practices. FRA does not have authority to enforce the AAR Interchange Rules or 

the AAR Manual of Standards and Recommended Practices. However, the AAR requirements 

provide valuable insight into railroad equipment and operations as they exist in the industry. 

Federal and State inspectors must be able to assess an ever increasing variety of conditions and 

ascertain the necessity and type of corrective procedures to be initiated. Although § 215.7, 

Prohibited Acts, provides for strict liability, inspectors should always be governed by the seven 

factors listed in Part 209 Appendix A. 

MP&E inspectors must determine whether conditions observed acutely impact the safe operation 

of the freight equipment. When freight equipment is inspected and deficiencies exist, the 

inspector must decide whether the defect: 

 Is a Part 215 defect; 

 Should be documented on the F6180.96 - Inspection Report; 

 Warrants the issuance of a violation; 

 Warrants the issuance of a Special Notice for Repair; and/or 

 Should be reported to the railroad as an unsafe condition that is not encompassed in 

Federal regulations. (This could be either the railroad’s standards or AAR standards.) 

Note: In many instances, AAR requirements are more restrictive than Federal requirements. 

The following discussion summarizes guidelines to be used by Federal and State inspectors 

conducting field inspections for compliance or enforcement activity. Enforcement policies must 

be adhered to by each inspector conducting inspections of freight cars. It is the 

inspector’s responsibility to determine whether each unit is inspected, tested, maintained, or 

operated by railroad personnel complies with Federal regulations and is safe to operate over the 

general railroad system. 
Federal Railroad Administration 

4 - 2 

Determining Noncompliance

When an inspection reveals a noncomplying condition, the inspector must examine and 

determine the particular details of the condition in order to assess whether it conforms with the 

current interpretations and guidelines issued by FRA. Before recording the condition as a defect, 

the inspector must weigh each essential factor to determine whether the condition meets, 

exceeds, or is noncompliant with Federal regulations. If the inspector determines that a 

condition is unsafe or creates an imminent hazard and is not covered by Federal regulations, he 

or she should inform a responsible railroad official of the need for corrective action. This could 

be based on the railroad’s standard or an AAR requirement. 

When a measurement is required to determine compliance or noncompliance and such 

measurement cannot be accurately stated as meeting or exceeding those measurements contained 

in the applicable regulation, then that condition must not be reported as a defect. 

When the inspector determines and documents that a freight car is noncompliant with Federal 

regulations, he or she should consider filing appropriate reports (based on the situation). To 

determine what enforcement action to employ, the inspector should consider the compliance 

history at the location and whether or not the railroad immediately initiates corrective action. If 

the inspector concludes a violation is warranted, then only one written violation report can be 

issued per car. The violation report can contain multiple counts for defective conditions, but do 

not issue multiple violation reports for an individual car. If the noncomplying condition for a 

violation can be proven to have existed for multiple days, then the one violation report should 

indicate how many days the car was in violation. Do not issue a separate violation report for 

each day the car is determined to be in noncompliance. 

Additionally, if the inspector determines that a freight car is noncompliant with Federal 

regulations, is unsafe, and presents an imminent safety hazard; and if the inspector has reason to 

believe that the railroad will not take immediate corrective action, a Special Notice for Repair

should be issued to the railroad. The inspector should enumerate each serious condition in the 

notice. See 49 CFR part 216. Except in rare circumstances, a violation report must be 

submitted with a Special Notice for Repair. 

Inspection of freight cars that have been repaired and released by car repair facilities should be 

done on a regular basis. These freight cars should be suitable for service and free of all defects. 

If defects are found, violations should be submitted. This inspection must take place after the car 

is moved from the shop or repair track area. 

An individual who willfully authorizes movement or operation of noncomplying or unsafe 

equipment, with knowledge of the circumstances, can be held personally liable for such action. 

Inspectors should carefully weigh all pertinent facts before considering a willful violation of 

Federal regulations and/or an individual liability action. The inspector must communicate with 

the FRA regional office prior to advising a railroad employee that he or she will be cited with an 

individual liability violation. 
Motive Power and Equipment Compliance Manual 

4 - 3 

Freight Car Safety Standards Inspection Procedures

Upon arrival at an inspection point, inspectors should notify the local railroad representative of 

their presence and intentions, determine what equipment will be inspected, and ask the railroad 

representatives if they plan to accompany the inspection. However, it is not always 

advantageous to be accompanied on inspections or notify the railroad of FRA presence, 

especially if an inspection is related to a complaint or investigation. 

Generally, inspectors should focus Part 215 inspection activities on cars after the railroad’s 

personnel or agents have had an opportunity to perform their inspection of the cars. However, 

performing inspections on inbound trains can be advantageous to determine the quality of 

inspections at previous locations where cars are placed in trains. Inspections should also be 

performed at any location where cars are routinely picked up and placed in trains. 

Inspectors must be properly attired and comply with the railroad’s safety requirements (e.g., 

safety glasses, hard hat, safety shoes, etc.). Inspectors should also have in their possession the 

necessary gauges, flashlight, ruler and/or tape measure, camera, and a current copy of the 

regulations. Do not use the railroad’s gauges for enforcement activities. 

It is not necessary for FRA or State inspectors to establish blue signal protection in order to 

perform inspection activity. However, inspectors should never place themselves in a position 

where the unexpected movement of equipment subjects them to the danger of personal injury. 

Railroad representatives accompanying the inspector during the inspection must obtain blue 

signal protection if those individuals engage in activities that require them to work on, under, or 

between the equipment. 

 

Regulation 

PART 215 - Railroad Freight Car Safety Standards 

§215.3 Application 

(a) Except as provided in paragraphs (b) and (c) of this section, this part applies to each railroad 

freight car in service on: 

(1) Standard gage track of a railroad; or 

(2) Any other standard gage track while the car is being operated by, or is otherwise 

under the control of a railroad. 

(b) Sections 215.15 and 215.303 of this part do not apply to any car: 

(1) Owned by a Canadian or Mexican Railroad; and 

(2) Having a Canadian or Mexican reporting mark and car number. 

(c) This part does not apply to a railroad freight car that is: 

(1) Operated solely on track inside an industrial or other non-railroad installation; or 

(2) Used exclusively in dedicated service as defined in §215.5(d) of this part; or 
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(3) Maintenance-of-way equipment (including self-propelled maintenance-of-way 

equipment) if that equipment is not used in revenue service and is stenciled in accordance 

with §215.305 of this part. 

§215.5 Definitions. 

As used in this part: 

(a) Break means a fracture resulting in complete separation into parts; 

(b) Cracked means fractured without complete separation into parts, except that castings with 

shrinkage cracks or hot tears that do not significantly diminish the strength of the member are not 

considered to be “cracked,” 

(c) Railroad freight car means a car designed to carry freight, or railroad personnel, by rail and 

includes a: 

(1) Box car; 

(2) Refrigerator car; 

(3) Ventilator car; 

(4) Stock car; 

(5) Gondola car; 

(6) Hopper car; 

(7) Flat car; 

(8) Special car; 

(9) Caboose car; 

(10) Tank car; and 

 (11) Yard car. 

Guidance

A ventilator car is a car that is arranged for ventilation and suitable for the transportation of 

produce or other foodstuffs not requiring refrigeration. A special car includes articulated cars, 

scale cars, intermodal-carless equipment (RoadRailerTM), and any car not listed in this section. A 

yard car is any car used exclusively in yard service. In intermodal-carless equipment operations, 

the highway trailer is treated as the car body for the purposes of Part 215 when it is attached to 

the bogie on the rail. Part 215 does not apply to any type of car operated in a passenger train 

that is inspected, tested, maintained, and operated pursuant to the requirements contained in the 

Passenger Equipment Safety Standards, Part 238.
Motive Power and Equipment Compliance Manual 

4 - 5 

Regulation

(d) Dedicated service means the exclusive assignment of cars to the transportation of freight 

between specified points under the following conditions: 

(1) The cars are operated— 

(i) Primarily on track that is inside an industrial or other non-railroad installation; 

and 

(ii) Only occasionally over track of a railroad; 

(2) The cars are not operated— 

 (i) At speeds of more than 15 miles per hour; and 

 (ii) Over track of a railroad— 

 (A) For more than 30 miles in one direction; or 

 (B) On a round trip of more than 60 miles; 

(3) The cars are not freely interchanged among railroads; 

(4) The words “Dedicated Service” are stenciled, or otherwise displayed, in clearly 

legible letters on each side of the car body; 

(5) The cars have been examined and found safe to operate in dedicated service; 

(6) The railroad must— 

(i) Notify the FRA in writing that the cars are to be operated in dedicated service; 

(ii) Identify in that notice— 

 (A) The railroad affected; 

 (B) The number and type of cars involved; 

 (C) The commodities being carried; and 

 (D) The territorial and speed limits within which the cars will be 

 operated; and 

(iii) File the notice required by this paragraph not less than 30 days before the cars 

operate in dedicated service; 

(e) In service when used in connection with a railroad freight car, means each railroad 

freight car subject to this part unless the car: 

(1) Has a “bad order” or “home shop for repairs” tag or card containing the prescribed 

information attached to each side of the car and is being handled in accordance with 

§215.9 of this part; 

(2) Is in a repair shop or on a repair track; 

(3) Is on a storage track and is empty; or 

(4) Has been delivered in interchange but has not been accepted by the receiving carrier. 
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Guidance

The Federal Register Notice dated April 21, 1980 (45 FR 26709), states that “FRA has amended 

215.5(e)(4) to provide that a car that has been delivered in interchange is not ‘in service’ until the 

receiving railroad accepts the car by moving it or otherwise exercising control over it. It should 

be noted, however, that the delivering railroad remains liable for each defective car it tenders in 

interchange.” (MP&E 98-34)

Regulation

(f) Railroad means all forms of non-highway ground transportation that run on rails or 

electromagnetic guide-ways, including (1) commuter or other short-haul rail passenger service in 

a metropolitan or suburban area, and (2) high speed ground transportation systems that connect 

metropolitan areas, without regard to whether they use new technologies not associated with 

traditional railroads. Such term does not include rapid transit operations within an urban area 

that are not connected to the general railroad system of transportation. 

(g) State inspector means an inspector who is participating in investigative and surveillance 

activities under section 206 of the Federal Railroad Safety Act of 1970 (45 U.S.C. 435). 

§215.9 Movement of defective cars for repair. 

(a) A railroad freight car which has any component described as defective in this part may be 

moved to another location for repair only after the railroad has complied with the following: 

 (1) A person designated under §215.11 shall determine: 

 (i) That it is safe to move the car; and 

 (ii) The maximum speed and other restrictions necessary for safely conducting 

 the movement; 

(2) (i) The person in charge of the train in which the car is to be moved shall be 

notified in writing and inform all other crew members of the presence of the 

defective car and the maximum speed and other restrictions determined under 

paragraph (a)(1)(ii) of this section. 

(ii) A copy of the tag or card described in paragraph (a)(3) of this section may be 

used to provide the notification required by paragraph (a)(2)(I) of this 

section. 

(3) A tag or card bearing the words “bad order” or “home shop for repairs” and 

containing the following information, shall be securely attached to each side of the 

car: 

 (i) The reporting mark and car number; 

 (ii) The name of the inspecting railroad; 

 (iii) The inspection location and date; 

 (iv) The nature of each defect; 

 (v) Movement restrictions; 

 (vi) The destination for shopping or repair; and 

 (vii) The signature of a person designated under §215.11. 
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4 - 7 

(b) (1) The tag or card required by paragraph (a)(3) of this section may only be removed 

from the car by a person designated under §215.11 of this part. 

(2) A record or copy of each tag or card attached to or removed from a car shall be 

retained for 90 days and, upon request, shall be made available within 15 calendar days 

for inspection by FRA or State inspectors. 

(3) Each tag or card removed from a car shall contain a notification stating the date, 

location, reason for its removal, and the signature of the person who removed it from the 

car. These recordkeeping requirements have been approved by the Office of Management 

and Budget in accordance with the Federal Reports Act of 1942. 

(c) Movement of a freight car under paragraph (a) of this section may be made only for the 

purpose of effecting repairs. If the car is empty, it may not be placed for loading. If the car is 

loaded, it may not be placed for unloading unless unloading is consistent with determinations 

made and restrictions imposed under paragraph (a)(1) of this section and— 

 (1) The car is consigned for a destination on the line of haul between the point where the 

car was found to be defective and the point where repairs are made; or 

 (2) Unloading is necessary for the safe repair of the car. 

(d) Nothing in this section authorizes the movement of a freight car subject to a Special Notice 

for Repairs unless the movement is made in accordance with the restrictions contained in the 

Special Notice. 

Guidance

If the car is prepared as outlined under §215.9, it may be moved to any location designated by 

the railroad for the purpose of effecting repairs. This does not have to be the nearest or next

repair location. The car may be moved to another railroad and can be moved past repair 

locations. The car must be inspected and cards applied to both sides of the car by a designated 

inspector, as defined in §215.11, before movement can take place. Movement authority by 

§215.9 applies only to Part 215 defects, not safety appliance or power brake defects. Failure to 

observe any condition for movement set forth in §215.9(a) and (c) deprives the railroad of the 

benefit of the “movement-for-repair” provision and makes the railroad and any responsible 

individual liable for penalty under the particular regulatory sections that apply to the defective 

condition. For example, a car with a defective roller bearing adapter travels beyond the repair 

location designated on the “bad order” card. 

Do not issue a violation for the movement of defective equipment; instead, issue the violation for 

the defective condition – defective roller bearing adapter. The regulation does not prevent the 

railroad from changing the repair location, as long as all of the conditions of §215.9 are satisfied. 

The purpose of the defect tag is to notify the operating crews and mechanical department 

personnel of the defective condition, and that the car is safe to move, along with any movement 

restrictions. Inspectors should periodically check defect tags to verify that they are completely 

filled out by a person designated under §215.11. 

 
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Regulation

§215.11 Designated inspectors. 

(a) Each railroad that operates railroad freight cars to which this part applies shall designate 

persons qualified to inspect railroad freight cars for compliance with this part and to make 

determinations required by §215.9 of this part. 

(b) Each person designated under this section shall have demonstrated to the railroad a 

knowledge and ability to inspect railroad freight cars for compliance with the requirements of 

this part and to make determinations required by §215.9 of this part. 

(c) With respect to designations under this section, each railroad shall maintain written records 

of: 

(1) Each designation in effect; and 

(2) The basis for each designation. 

Guidance

The railroad must maintain a record that contains the names of the inspectors that are designated 

under §215.11, which can be readily produced for FRA review. This includes contractors, train 

crew members, or any individual that has demonstrated to the railroad the knowledge and ability 

to perform all of the functions listed in Part 215. Only persons that are listed as designated 

inspectors can make the determinations required by §215.9. The railroad establishes the basis for 

each designation in effect. A person performing an Appendix D inspection cannot make the 

determination for movement under §215.9. However, if a train crew member is listed as a 

designated inspector, he or she can make the determination for movement under §215.9, but 

would be required to perform a full inspection for compliance with this Part, not an Appendix D 

inspection. 

Regulation

§215.13 Pre-departure inspection. 

(a) At each location where a freight car is placed in a train, the freight car shall be inspected 

before the train departs. This inspection may be made before or after the car is placed in the 

train. 

(b) At a location where an inspector designated under §215.11 is on duty for the purpose of 

inspecting freight cars, the inspection required by paragraph (a) of this section shall be made by 

that inspector to determine whether the car is in compliance with this part. 

(c) At a location where a person designated under §215.11 is not on duty for the purpose of 

inspecting freight cars, the inspection required by paragraph (a) shall as a minimum, be made for 

those conditions set forth in Appendix D to this part. 
Motive Power and Equipment Compliance Manual 

4 - 9 

(d) Performance of the inspection prescribed by this section does not relieve a railroad of its 

liability under §215.7 for failure to comply with any provision of this part. 

Guidance

The language of §215.13 is very explicit. FRA has consistently interpreted this language to 

require a pre-departure inspection each time a car is placed in a train. Moreover, although the 

regulations do not specify the physical actions necessary to conduct a proper inspection, a 

railroad may fulfill the inspection requirements only when its inspectors position themselves in a 

way that permits the required observations to be made. In order to conduct a proper freight car 

safety standards inspection, both sides of a car must be inspected. 

Section 215.13 does not permit block swapping. At some locations a common misinterpretation 

of the words “placed in a train” has led to the practice of allowing new outgoing trains to be built 

from large blocks of cars from two or more incoming trains without performing a pre-departure 

inspection. Within the industry, this practice is called “block swapping.” This misinterpretation 

of the regulation apparently assumes that a car that remains in a block of cars when it is removed 

from one train is not “placed in a train” when the block is added to a new train. That assumption 

is incorrect. Whether singly or in groups, cars that are taken from one train and placed in another 

are “placed in a train” and must be inspected at the location from which the new train departs. 

Of course, an inspection pursuant to §215.13 is not required when intact trains move from 

railroad to railroad. 

However, as with any regulatory requirement, inspectors should exercise discretion in how 

§215.13(a) is enforced, so that our limited resources can remain focused on matters likely to 

produce the greatest safety benefit. The general criteria for determining when enforcement 

action is appropriate, and which action to take, are set forth in 49 CFR Part 209, Appendix A. 

The railroad’s history of compliance with the relevant set of regulations, especially at the 

specific location involved, must be considered along with the kind and degree of potential safety 

hazard a condition poses in light of the immediate factual situation. Where compliance with the 

Freight Car Safety Standards is poor and improper inspections or no inspections are being 

performed, the failure to inspect or improper inspection can be (along with the physical defects 

found on the cars) strong enforcement candidates. Conversely, if a railroad is generally doing a 

good job in terms of compliance with the Freight Car Safety Standards at a particular location, 

the one-time failure to conduct a proper inspection at that point is more likely not a condition 

that poses a significant safety hazard. (MP&E 98-57)

Section 215.13(a) requires an inspection at each location where a freight car is placed in a train. 

However, in some circumstances the inspection may be performed by a person not qualified or 

designated under §215.11. The law does not require that a “designated inspector” under §215.11 

be assigned or employed at every location where cars are added to trains. Consequently, a train 

crewmember who is not a designated inspector under §215.11 can perform an inspection of 

freight cars added to a train pursuant to Part 215, Appendix D, at a location where a person 

designated under §215.11 is not on duty for the purpose of inspecting freight cars. However, if a 

location does not have a person designated under §215.11 on duty for the purpose of inspecting 
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4 - 10 

freight cars and the railroad elects to conduct such an inspection with a non-designated person 

pursuant to Part 215, Appendix D, and if such an inspection uncovers a condition not in 

compliance with Part 215 or Appendix D, then in order to move the car for repair under §215.9, 

a designated person under §215.11 must determine whether it is safe to move the car and, if so, 

under what conditions. 

Part 215 does not dictate when and where railroads must have designated inspectors on duty for 

the purpose of inspecting freight cars. Section 215.13 merely requires that, where such a person 

is not on duty for that purpose, the railroad must conduct an Appendix D inspection. Where 

there is a dispute between a railroad and its employees as to which employee is on duty for what 

purpose, that issue must be resolved as a collective bargaining matter. Absent such a binding 

resolution from a body duly authorized to render such rulings, FRA is in no position (under 

current law) to conclude that an employee is on duty for the purpose of inspecting freight cars, if 

the railroad contends that the person is not on duty for that purpose. Once a final, binding 

determination is obtained, it would presumably be enforceable on its own terms by those who 

sought it. Although Part 215 was not intended to put FRA in the position of dictating where a 

railroad uses its designated inspectors, it is clear that the railroad must designate qualified 

inspectors, keep records of the designations, and at the very least, use such inspectors to make 

the determinations required under §215.9 before a defective car can be moved. 

At locations where cars are inspected by railroad personnel who are not designated inspectors, 

the options for handling the defective cars are limited to: (1) Setting the car out, (2) repairing the 

car, or (3) bringing in a designated inspector to either repair the car or prepare the car for 

movement to a repair facility in accordance with §215.9. 

The regulation states that the pre-departure inspection may be made before or after the car is 

placed in the train. Therefore, the requirements for this inspection can be met by performing an 

inbound inspection before the cars are classified and placed into a new train. 

Regulation

§215.15 Periodic inspection. - This part is no longer applicable. 

Suspension System. 

§215.103 Defective wheel. 

A railroad may not place or continue in service a car, if- 

 (a) A wheel flange on the car is worn to a thickness of 7⁄8 of an inch, or less, at a point 3⁄8 

 of an inch above the tread of the wheel; 

 (b) The height of a wheel flange on the car, from the tread to the top of the flange, is 11⁄2 

 inches, or more; 

 (c) The thickness of a rim of a wheel on the car is 11/16 of an inch, or less; 
Motive Power and Equipment Compliance Manual 

4 - 11 

 (d) A wheel rim, flange, plate, or hub area on the car has a crack or break; 

(e) A wheel on the car has a chip or gouge in the flange that is 11⁄2 inches in length and 1⁄2 

inch in width, or more; 

 (f) A wheel on the car has—— 

 (1) A slid flat or shelled spot that is more than 21⁄2 inches in length; or 

(2) Two adjoining flat or shelled spots each of which is more than two 

 inches in length; 

(g) A wheel on the car shows evidence of being loose such as oil seepage on the back hub or 

back plate; 

(h) A wheel on the car shows signs of having been overheated as evidenced by a reddish 

brown discoloration, to a substantially equal extent on both the front and the back face of 

the rim, that extends on either face more than four (4) inches into the plate area measured 

from the inner edge of the front or back face of the rim; or, 

(i) A wheel on the car has been welded unless the car is being moved for repair in 

accordance with §215.9 of this part. 

Guidance

The specified wheel measurements are the minimum safety requirements and are designed to 

prevent wheel failures and train derailments. Wheel measurements must be carefully taken to 

assure accuracy. To determine if a locomotive or freight car wheel is in compliance, a standard 

application of wheel gages is equally as important as having standard gages. 

To gage a wheel for thin flange, the 7⁄8-inch opening of the AAR 34401 gage should slip over the 

flange of the wheel when the gage is held with the flat surface at the top, perpendicular to the 

tread (see Figure 1). The unused bulk of the gage must be suspended behind the back face of the 

rim. Gaging in a chipped area is not acceptable. 

Figure 1: Gaging wheel thin flange 
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4 - 12 

A high flange wheel shall be gaged with a simplified steel wheel gage (hook gage) (see Figure 

2). The shank, or long flat portion of the gage, must be held flat against the back face of the rim 

and parallel to the radius of the wheel. The defective flange will contact the hook portion of the 

gage, and the tip of the gage will contact the tread of the wheel or be held clear from the tread. 

Gaging in a flat spot or shelled spot is not acceptable. 

Figure 2: Gaging of wheel high flange 

A thin rim wheel can be properly gaged with a W804 gage. It is suggested that if the inspector 

does not have a W804 gage, they should mark a simplified steel wheel gage 1/16 of an inch 

above the 3⁄4-inch mark. This will allow them to make a close evaluation of an 11/16-inch rim. 

However, it is not recommended that a violation be submitted when using a non-calibrated gage. 

The gage is to be applied to the wheel in the same manner as that used for gaging a high flange, 

and the gaging point would be the abrupt angle at the inside of the back face of the rim. With the 

gage held firmly against the back face of the rim, parallel to the radius and the point resting on 

the tread of the wheel, the reading should be 11/16 of an inch or less for a defective condition 

(see Figure 3). Gaging with the tip or point of the gage in a flat spot or shelled spot is not 

acceptable. 

Figure 3: Gaging of when thin flange. 
Motive Power and Equipment Compliance Manual 

4 - 13 

A flat spot on a wheel may be gaged with AAR gage 34401. The flat portion of the gage is 

marked in such a way that a 21⁄2-inch flat spot can be easily measured. This portion of the gage 

must be applied to the flat spot on the wheel with absolutely no rocking motion allowable within 

the 21⁄2-inch area (see Figure 4). Two adjoining flat spots, 2 or more inches in length, are 

measured using the same method. 

Figure 4: Gaging of flat spot 

The overheated wheel requires a higher degree of judgment because of the varying degrees of 

discoloration. A reddish-brown discoloration that extends into the wheel plate more than 4 

inches on both sides of the wheel indicates an overheated condition. The discoloration should 

come toward the center of the wheel 4-inches inside the rim before exceptions are taken. The 4-

inch measurement is to be made from the bottom of the back face of the rim. A rust condition of 

the wheel should not be considered as a reddish brown discoloration. 

There is currently a waiver in place that exempts “heat treated-curved plate” (HT-CP) wheels 

from the requirements of §215.103(h), provided the HT-CP wheel is clearly identified by an “H” 

painted or stencilled on the outside plate of the wheel. 

Welded wheels. Regulations allow the welding of wheels only as an emergency measure to 

enable the car to be moved to a repair facility. A welded wheel is not a prohibited defect if the 

car is tagged and being moved in accordance with §215.9 for the purpose of replacing the wheel. 

It is not acceptable to place a gage on a wheel in such a way that it takes a combination of two or 

more conditions to condemn it as defective (i.e., gaging for high flange in a flat spot). (MP&E 

98-10)

Regions shall ensure that their inspectors have calibrated wheel gages and know how the gages 

are to be applied to the wheel in order to determine if the wheel is in compliance with the 

regulations. 

After finding a statistically elevated number of vertical split rim failures (see Figure 5) on 36-

inch Southern wheels of various ages, the AAR has issued instructions that all 36-inch Southern 

wheels are to be pulled from service when at a wheel shop. Also, Southern CH-36 wheels made 
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4 - 14 

in 1995 are to be pulled from service when on a shop or repair track for any reason. Failure to 

follow these AAR instructions is not an FRA defect, but if observed, should be brought to the 

attention of the railroad. 

Figure 5: Split rim wheel failure 

Other Wheel Failures

Shattered rims (see Figure 6) occur due to subsurface defects in the wheel. They are often first 

observable as a crack on the side of the rim, running basically parallel to the tread, (as shown 

between the chalk marks in the picture on Figure 7). Telltale rust streaks can help to identify 

them. The failure is not always as benign as the one shown here, with only a small portion of the 

tread missing. Often, major sections of the tread break away, similar to the vertical split rim 

shown above. Occasionally, the plate of the wheel also fails and there is not much left except the 

hub. 

Figure 6: Shattered rim wheel 
Motive Power and Equipment Compliance Manual 

4 - 15 

Figure 7: A crack on the side of the rim and runs parallel to the tread could lead to shattered rim 

Wheel Thermal Cracks and Heat Checks

The distinction between thermal cracks and heat checks on the tread of a wheel has been a 

difficult one to make. Due to recent disputes between at least one major railroad and car owner 

over billing for wheel replacements it is currently under study by the AAR’s Wheels Axles 

Bearings and Lubrication (WABL) Committee. 

 

A wheel that has been severely overheated loses its residual compressive stress in the tread 

surface and develops cracking parallel to the axle. Since the surface has gone into tension, the 

cracks open and can be felt with a fingernail running over the surface. Less severe overheating 

can result in heat checks, which are visible lines on the tread surface that do not open into cracks 

since the wheel has not been overheated to the point that the residual compressive stress in the 

tread is lost. These lines do not feel rough when a fingernail dragged over them. They are 

typically not parallel to the axle, but instead run at an angle across the tread. Heat checks may 

develop into shelled tread, but they are not believed to develop into cracks unless further severe 

overheating of the wheel occurs. 

Recently, considerable controversy has arisen over lines which were found parallel to the axle, 

like thermal cracks, but which remained closed like heat checks. Wheel experts from the 

Transportation Technology Center determined that since there was no evidence of the surface 

being in tension, these lines were heat checks. A Technical Action Group (TAG) was formed by 

the WABL Committee to settle this dispute. All concerned agree that the pictures contained in 

the current edition of the AAR Field Manual are inadequate and will need to be replaced. 

Regulation

§215.105 Defective axle and journal 
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4 - 16 

A railroad may not place or continue in service a car, if - 

(a) An axle on the car has a crack or is broken; 

(b) An axle on the car has a gouge in the surface that is - 

(1) Between the wheel seats; and 

(2) More than one-eighth inch in depth; 

(c) An axle on the car, used in conjunction with a plain bearing, has an end collar that is broken 

or cracked; 

(d) A journal on the car shows evidence of overheating, as evidenced by a pronounced blueblack discoloration; or 

(e) The surface of the plain bearing journal on the axle, or the fillet on the axle, has- 

(1) A ridge; 

 (2) A depression; 

(3) A circumferential score; 

 (4) Corrugation; 

 (5) A scratch; 

(6) A continuous streak; 

 (7) Pitting; 

 (8) Rust; or 

(9) Etching. 

§215.107 Defective plain bearing box: General. 

A railroad may not place or continue in service a car, if the car has- 

(a) A plain bearing box that does not contain visible free oil; 

(b) A plain bearing box lid that is missing, broken, or open except to receive servicing; 

or 

(c) A plain bearing box containing foreign matter, such as dirt, sand, or coal dust, that 

can be reasonably be expected to- 

(1) Damage the bearing; or 

(2) Have a detrimental effect on the lubrication of the journal and the bearings. 

Guidance

A plain bearing box that contains a significant amount of water should be treated as foreign 

matter. The journal should be inspected with a wire feeler hook to determine if there is pitting. 

Regulation

§215.109 Defective plain bearing box: Journal lubricating system. 
Motive Power and Equipment Compliance Manual 

4 - 17 

A railroad may not place or continue in service a car, if the car has a plain bearing box with a 

lubricating pad that- 

(a) Has a tear extending half the length or width of the pad, or more; 

(b) Shows evidence of having been scorched, burned, or glazed; 

(c) Contains decaying or deteriorated fabric that impairs proper lubrication of the pad; 

(d) Has- 

(1) An exposed center core (except by design); or 

(2) Metal parts contacting the journal; or 

(e) Is- 

(1) Missing; or 

(2) Not in contact with the journal. 

Guidance

Currently, AAR Interchange Rule 88 requires that all hazardous material tank cars in service 

must be equipped with roller bearings. Also, all freight cars offered for interchange service must 

be equipped with roller bearings. Although this is not a Federal defect, the railroad should be 

made aware of the situation whenever it is detected. 

Regulation

§215.111 Defective Plain Bearing. 

A railroad may not place in service or continue in service a car, if the car has a plain bearing- 

(a) That is missing, cracked or broken; 

(b) On which the bearing liner- 

(1) Is loose; or 

(2) Has a broken-out piece; or 

(c) That shows signs of having been overheated, as evidenced by- 

(1) Melted babbitt; 

(2) Smoke from hot oil; or 

(3) Journal surface damage. 

§215.113 Defective Plain Bearing Wedge. 

A railroad may not place or continue in service a car, if a plain bearing wedge on that car is- 

(a) Missing; 

(b) Cracked; 

(c) Broken; or 

(d) Not located in its design position. 

§215.115 Defective Roller Bearing. 
Federal Railroad Administration 

4 - 18 

A railroad may not place or continue in service a car, if the car has- 

(1) A roller bearing that shows signs of having been overheated as evidenced by- 

(i) Discoloration; or 

(ii) Other telltale signs of overheating such as damage to the seal or distortion of any 

bearing component; 

(2) A roller bearing with a- 

(i) Loose or missing cap screw; or 

(ii) Broken, missing, or improperly applied cap screw lock; or 

(3) A roller bearing with a seal that is loose or damaged, or permits leakage of lubricant in 

clearly formed droplets. 

(b)(1) A railroad may not continue in service a car that has a roller bearing whose truck 

was involved in a derailment unless the bearing has been inspected and tested by: 

(i) Visual examination to determine whether it shows any sign of damage; and 

(ii) Spinning freely its wheel set or manually rotating the bearing to determine 

whether the bearing makes any unusual noise. 

(4) The roller bearing shall be disassembled from the axle and inspected internally if- 

(i) It shows any external sign of damage; 

(ii) It makes any unusual noise when its wheel set is spun freely or the bearing is 

manually rotated; 

(iii) Its truck was involved in a derailment at a speed of more than 10 miles per 

hour; or 

(iv) Its truck was dragged on the ground for more than 200 feet. 

(5) Each defective roller bearing shall be repaired or replaced before the car is placed back in 

service. 

Guidance

Some loss of lubricant through “seepage” around a roller bearing seal may not be hazardous and 

should not be reported as a defect. A seal that “permits leakage of a significant amount of 

lubricant in clearly formed droplets” is defective. “Clearly formed droplets” means a fresh

accumulation of grease/oil (not dirty or dried) that continually leaks out from the bearing and/or 

slowly forms into beads. A careful examination should be made of any roller bearing from 

which “fresh” or “new” lubricant is thrown onto wheels, truck components, or the car body. A 

seal that is “loose, damaged, or non-functioning” is considered to be defective. 

A loose backing ring is not to be reported as a defective bearing, but should be brought to the 

attention of the railroad, as the AAR identifies this condition as cause for removal in their 

Interchange Rules. Additionally, the inspector should note this condition as a comment on the 

F6180.96 report. 
Motive Power and Equipment Compliance Manual 

4 - 19 

When a railroad opts to rotate the roller bearing manually, rather than rotating the wheel 

assembly to detect a defective condition due to a derailment, care must be exercised because the 

presence of lubricant and the fact that the bearing is not under load tend to reduce sounds made 

by small defects. When the wheel assembly is rotated, the weight on the bearing magnifies the 

sound. 

 

NOTE: During an inspection on a shortline railroad, it was discovered that some tank cars 

equipped with roller bearings were derailed and sustained damages. These cars were not 

repaired and the roller bearings were not examined as required prior to delivery to a connecting 

railroad. Also, the shortline railroad did not advise the receiving railroad of the derailment 

damage and associated damages. If a train crew performing an Appendix D inspection at the 

interchange point did not detect the defective condition of these cars, the cars would have 

continued in service in a defective condition. 

Many shortline railroads operate over “Excepted Track” that often is the cause of derailments. 

Further, some shortline railroads do not have qualified inspectors or repair facilities to address 

defective conditions. Some shortlines have agreements with the interchange railroads to effect 

repairs to defective cars that fall under their responsibility. Due to the seriousness of a car with a 

defective bearing condition continuing in service and/or the possible failure of a shortline to 

notify the receiving railroad of a potential defective car, inspectors should review the proper 

handling of derailed cars and defective cars with each shortline railroad within their territory. 

(MP&E 98-29)

As recently as 2008, overheated journal bearings (Reporting Code E53C) were the most common 

mechanical cause of derailments, despite the presence of many hot box detectors on the railroads. 

Within the following years, the number of derailments caused by hot journal boxes has been 

significantly reduced, as shown in the table that follows. 

Year 2008 2009 2010 2011 

E53C Journal 

(roller bearing) 

overheated 

27 25 12 2 (Jan) 

Railroad representatives to AAR’s WABL Committee attribute this to the increased effectiveness 

of wayside detector systems, including hot box detectors and wheel impact load detectors 

(WILD). Although hot box detectors have been in use for many years, it is only recently that the 

railroads have been networking the detectors and analyzing the data in real time to identify 

dangerous temperature trends and set out “warm” bearings before they burn off. This technology 

remains unable to predict “quick burns,” an issue that the industry is still attempting to address. 

Although a relationship has not been proven, the WILD detectors are thought to be benefiting 

bearings because they identify high-impact wheels so they can be removed from service before 

the pounding causes bearing damage. 
Federal Railroad Administration 

4 - 20 

Regulation

§215.117 Defective Roller Bearing Adapter. 

A railroad may not place or continue in service a car, if the car has a roller bearing adapter that 

is- 

(a) Cracked or broken; 

(b) Not in its design position; or 

(c) Worn on the crown of the adapter to the extent that the frame bears on the relief portion of 

the adapter. 

Guidance

Appropriate enforcement action must be taken if a car has a roller bearing adapter that is out of 

place or has excessive wear on the crown of the adapter. Either condition can cause uneven load 

distribution on the bearing and result in bearing failure. 

Roller bearing adapter pads designed with a square surface depression of about 5 inches and 

about 3/16 inch deep were at one time common on articulated equipment. They had a high 

failure rate and an effort was made to replace them with a specially designed adapter. The pad 

was designed to fit in the 5-inch square depression of the roller bearing adapter and act as the 

crown for proper contact with the truck side frame roof. There were at least three pad designs. 

The two with the highest failure rate were made to look like a square plate about 3/8-inch thick, 

and consisted of metal plates and a plastic material which was found to crush and deteriorate. 

The other pad design was a rounded plate about 3/8-inch thick with squared shoulders for 

retention in the adapter depression. Complete failure of the pad will leave a flat surface on the 

top side of the adapter where the crowned surface should be in contact with the truck side frame 

roof. Partial failure will tend to concentrate the off-center loading to the part of the pad that has 

not failed. This creates a potential roller bearing failure. Defective conditions can be easily 

detected by close inspection. There should be a void between the adapter and the side frame 

roof, except where the pad is the buffer between the two. The pad should provide enough 

thickness in the center to act as the crown of the adapter. If these pads are found defective they 

should be reported on the appropriate inspection report using code 215.117(E)(1) “Roller bearing 

adapter resilient wear plate (vertical isolation pad) defective or not in its designed position.” 

(MP&E 98-21) 

Adapter wear plates (roof liners) should be examined as to their condition and effectiveness. 

Since the regulation requires the roller bearing adapter to be in its designed position, if a problem 

exists, a defect should be taken. 

There are cars in service that are designed to operate with a single axle wheel set at each end. 

The truck bearing cup filler blocks, commonly referred to as roller bearing adapter blocks, are 

located beneath the roller bearing rather than on top of the bearing, as found on conventional 

freight car equipment, and are secured in place by a single bolt or pin and cotter key (see Figure8). When the adapter block is missing, the adapter may become unseated from its designed 
Motive Power and Equipment Compliance Manual 

4 - 21 

location or be missing completely. When this condition is detected, take appropriate action and 

report the condition as set forth in 49 CFR §215.117 (roller bearing adapters). 

Figure 8: 

Single axle 

wheel set’s carbody-pedestal securement and bearing cup filler block 

Another condition that has been discovered with this type of truck is loose and missing pedestal 

securement bolts. Each side of the pedestal is attached to the car body, see Figure 8, by four 

bolts measuring 47⁄8 inch each. Bolts have been found loose, broken, and missing. This 

noncomplying condition can be reported on Form F6180-96 using code 215.121(F)(1). (MP&E 

98-42) 

The vertical isolation pads (adapter pads) that were primarily found on articulated 125 ton double 

stack cars are now prohibited in interchange by the AAR.

Regulation

§215.119 Defective Freight Car Truck. 

A railroad may not place or continue in service a car, if the car has- 

(a) A side frame or bolster that- 

(1) Is broken; or 

Truck Bearing Cup

 Filler Block Single Axle

Wheel Set

Single Axle

Wheel Set

Bolts

Securement Pedestal

To Carbody

Nuts
Federal Railroad Administration 

4 - 22 

(2) Has a crack of 1⁄4 of an inch or more in the transverse direction on a tension member 

(b) A truck equipped with a snubbing device that is ineffective, as evidenced by- 

(1) A snubbing friction element that is worn beyond a wear indicator; 

(2) A snubber wear plate that is loose, missing (except by design) or worn through; 

(3) A broken or missing snubber activating spring; or 

(4) Snubber unit that is broken, or in the case of hydraulic units, is leaking clearly 

formed droplets of oil or other fluid; 

(c) A side bearing in any of the following conditions: 

(1) Part of the side bearing assembly is missing or broken; 

(2) The bearings at one end of the car, on both sides, are in contact with the body bolster 

(except by design); 

(3) The bearings at one end of the car have a total clearance from the body bolster of 

more than 3⁄4 of an inch; or 

(4) At diagonal opposite sides of the car, the bearings have a total clearance from the 

body bolsters of more than 3⁄4 of an inch; 

(d) Truck springs- 

(1) That do not maintain travel or load; 

(2) That are compressed solid; or 

(3) More than one outer spring of which is broken, missing, in any spring cluster; 

(e) Interference between the truck bolster and the center plate that prevents proper truck 

rotations; or 

(f) Brake beam shelf support worn so excessively that it does not support the brake beam. 

Guidance

Truck Side Frame or Bolster

Freight car trucks side frame or truck bolster “broken” means it is separated into parts. 

Extensive cracking must be reported immediately as this condition can lead to rapid failure. 

A tension member (the diagonal portion of the side frame extending from the pedestal to the base 

of the spring pocket) must be cracked more than 1⁄4 inch in a transverse direction (right angle) 

before it can be considered defective. 

Snubbing Devices

The terms snubbing units, attachments, and wear plates, where used collectively, have been 

consolidated into one term: snubbing device. Friction-style snubbing devices with activating 

springs broken are defective. 
Motive Power and Equipment Compliance Manual 

4 - 23 

“Clearly formed droplets,” means a fresh accumulation of grease/oil (not dirty or dried) which 

continually leaks out and forms into beads. If it is just wet looking, it is not a defect. 

A car that has ineffective or broken snubbing devices will respond more violently to track 

irregularities and may cause a derailment. This would include the condition of a loose, missing, 

or worn through snubber wear plate. FRA has reviewed laboratory analyses on the subject of 

friction wedges that have added friction material, which are used on ABC-NACO Swing Motion 

trucks. The lab reports provided adequate evidence to conclude that there is no safety issue with 

composition friction material that is cracked, degraded, or missing from the wedge. Wedges that 

have loose composition layers provide adequate damping forces. Although new wedges generate 

greater damping forces than used wedges that have polished wear surfaces, a composition wedge 

that has all of its composition material removed still retains the damping characteristics of an allmetal wedge. Therefore, FRA will not take exception to degraded friction material condition on 

friction wedges used on ABC-NACO Swing Motion trucks. The wear indicator on the metal 

wedge is the qualifier. 

Hydraulic snubbing devices equipped with a “sight gauge” or “inspection window” that visibly 

indicates the presence of oil or other fluid when in a normal vertical position will not be 

considered as defective, regardless of presence of clearly formed droplets. The effectiveness of 

the device should be examined for tension, compression, movement, etc. 

Side Bearings

A missing or broken side bearing generates an uneven load distribution in the suspension system 

that could shift the lading. This, in turn, would cause the car to sway and derail. 

All side bearing measurements should be made when the car is placed on tangent and level track. 

All measurements must be made from the top of the truck side bearing roller or bearing surface 

in the cage, to the car body side bearing surface. This measurement is taken at opposite sides of 

the car or at one end of the car. The sum of either of the two measurements may not exceed 3/4 

inch. 

Although Federal regulations do not address specific measurement standards for constant contact 

side bearings, measurements have been established by the industry. The industry has developed 

special gages for qualifying constant contact side bearings. When inspectors identify constant 

contact side bearings that are worn beyond the manufacturer’s limits, then they are not in contact 

as designed and appropriate enforcement action should be taken. This is based on the language 

found in §215.119(c)(2) “...except by design.” All measurements must be taken on tangent 

level track. 

Guidance

Constant Contact Side Bearings
Federal Railroad Administration 

4 - 24 

Constant contact side bearings (CCSB) become condemnable when the measurements described 

below do not meet the specifications specified in the 2012 Field Manual of the Association 

American Railroads (AAR) Interchange Rules, Rule 62. 

1. All side bearing height measurements must be taken: 

 A. On tangent and level track 

B. Vertically between side bearing mounting surface and car body wear plate 

surface. 

 C. As close to the center of the side bearing as possible. 

2 CARS WITH 5 1/16 INCH SETUP HEIGHT AND 8 1⁄2” MOUNTING HOLES 

(Typically found on 4 axle cars and end trucks of articulated cars) 

A. Empty or loaded cars 

B. Side bearing is noncompliant if the “Sum-of-the-Pairs Measurement” is: 

(1). LESS than 9 3⁄4 inch 

(2). GREATER than 10 1⁄2 inch 

C. For articulated cars Sum-of-the-Pairs refers to side bearings laterally 

across from each other. 

D. For standalone cars, the following pairs must be summed: 

(1). AL+AR 

(2). BL+BR 

(3). AL+BR 

 (4). BL+AR 

E. Measure as shown in Figure 9 below. 

3. ARTICULATED CARS AT THE ARTICULATED TRUCK LOCATIONS: 

A. Side bearing is noncompliant if the “Sum-of-the-Pairs Measurement” is: 

Articulated Connector Nominal Set-Up Height

Or as stenciled on car Sum-of-the-Pairs Measurement
Motive Power and Equipment Compliance Manual 

4 - 25 

Female 5 1/6 inch Less than 9 3⁄4 inch

Greater than 10 3/8 inch 

Male 5 3/16 inch Less than 9 3⁄4 inch

Greater than 10 5/8 inch 

Female / Male Any Other 

Less than 9 3⁄4 inch

Greater than 1⁄4 inch above 2 

times the stenciled set-up height 

The Sum-of-the-Pairs refers to side bearings laterally across from each other.

B. Measure as shown in Figure 9 below:

Figure 9: Measurement of constant contact side bearing typically found on 4-axle cars and end 

trucks of articulated cars 

4. CARS WITH LOW PROFILE OR STANDARD HEIGHT SOLID BLOCK STYLE 

SIDE BEARING POCKETS. (Integral cast or welded on ring) 

A. Side bearing is noncompliant if the “Sum-of-the-Pairs Measurement” is: 

Side Bearing Manufacture Sum-of-the-Pairs Measurement 

(condemning limit) 

A. Stucki Less than 1 inch 

Greater than 1 3⁄4 inch 

Miner / Standard Truck Less than 7/8 inch 

Greater than 1 5/8 inch 

For standalone cars, the following pairs must be summed: 

AL+AR - BL+BR – AL+BR - BL+AR 

B. Measure as shown on Figure 10 below: 
Federal Railroad Administration 

4 - 26 

 Figure 10: Measurement of constant contact side bearing on cars with low profile or standard 

height solid block style side bearing pocket 

Truck Springs

Inner coil springs are not to be taken as a defect regardless of the number broken. One broken 

outer truck spring in a cluster does not create enough of an uneven load distribution to remove 

the car from service. Appropriate enforcement action must be taken if a car has more than one 

missing or broken outer truck spring within any cluster, or if the remaining truck springs are 

fully compressed. If the inspector detects evidence of springs oscillating in the spring nest, this 

is an indication that there is possible “truck hunting” problem and the inspector should make a 

comprehensive inspection of all truck components. 

Regulation

Car Bodies 

§215.121 Defective Car Body. 

A railroad may not place or continue in service a car, if: 

(a) Any portion of the car body, truck, or their appurtenances (except wheels) has less than a 21⁄2 

inch clearance from the top of the rail; 

(b) The car center sill is: 

(1) Broken; 

(2) Cracked more than 6 inches; or 

(3) Permanently bent or buckled more than 21⁄2 inches in any six foot length; 

(c) The car has a coupler carrier that is: 

(1) Broken; 
Motive Power and Equipment Compliance Manual 

4 - 27 

(2) Missing; 

(3) Non-resilient and the coupler has a type F head. 

(d) After December 1, 1983, the car is a box car and its side doors are not equipped with 

operative hangers, or the equivalent to prevent the doors from becoming disengaged. 

(e) The car has a center plate: 

(1) That is not properly secured; 

(2) Any portion of which is missing; or 

(3) That is broken; or 

(4) That has two or more cracks through its cross section (thickness) at the edge of the 

plate that extend to the portion of the plate that is obstructed from view while the truck is 

in place; or 

(f) The car has a broken sidesill, crossbearer, or body bolster. 

 

Guidance

The requirement for maintaining car body clearance of 21⁄2 inches is to ensure that car body 

items, including air hoses, are prevented from dragging on road crossings or track structures, 

which are a safety hazard. Heavy, depressed flat cars used in hauling heavy loads should be 

carefully inspected. 

Center Sills

A center sill is generally the central longitudinal member of the underframe of a car from striker 

to striker, which forms the backbone of the underframe and transmits buff and draft forces. 

A center sill “broken” means a fracture resulting in complete separation into parts. A condition 

of this nature could result in train separation or derailment. 

A center sill that is cracked more than 6 inches is defective. The integrity of the sill is 

compromised which can lead to total failure. 

A center sill bent or buckled more than 21⁄2 inches in any 6-foot length may undermine the 

integrity of the sill and result in a center sill failure. 

Similarly, in “sliding sill” designs, a single hydraulic unit is installed at the center of the car and 

acts to control longitudinal forces received at either end of an auxiliary center sill, which is free 

to travel longitudinally within a fixed center sill. This type of center sill should be inspected for 

defects such as, cracks more than 6 inches, bent or buckled more than 21⁄2 inches in any 6-foot 

length or broken. 

Coupler Carrier
Federal Railroad Administration 

4 - 28 

The design of an “F” type coupler head requires a spring loaded coupler carrier due to its locking 

characteristics. 

Door Safety Hangers

FRA considers door safety hangers to be one of the most critical safety requirements. A number 

of personal injuries and fatalities have occurred which involved doors falling off box cars. Door 

safety hangers must be capable of restraining the side door when the side door is in an open 

position and the bottom rollers of the door are off the door tracks. 

Regulation

Draft System 

§215.123 Defective Couplers 

A railroad may not place or continue in service a car, if- 

(a) The car is equipped with a coupler shank that is bent out of alignment to the extent that the 

coupler will not couple automatically with the adjacent car; 

(b) The car has a coupler that has a crack in the highly stressed junction area of the shank and 

head as shown in the figure below (see figure 2). 

(c) The car has a coupler knuckle that is broken or cracked on the inside pulling face of the 

knuckle. 

(d) The car has a knuckle pin or knuckle thrower that is: 

(1) Missing; or 

(2) Inoperative; or 

(e) The coupler has a retainer pin lock that is- 

(1) Missing; or 

(2) Broken; or 

(f) The car has a coupler with any of the following conditions: 

(1) The locklift is inoperative; 

(2) The coupler assembly does not have anti-creep protection to prevent unintentional 

unlocking of the coupler lock; or 

(3) The coupler lock is- 

(i) Missing; 

(ii) Inoperative; 

(iii) Bent; 

(iv) Cracked; or 

(v) Broken. 

 
Motive Power and Equipment Compliance Manual 

4 - 29 

Guidance

Based on laboratory test results, the following clarification is provided with respect to 

enforcement guidance for the removal of cracked couplers from service: 

A railroad may not place or continue in service a car that has a coupler that has a crack: 

 that extends beyond the shaded areas labelled (A) in Figure 10a; or 

 that extends 2 inches in length, or in additive length if more than one crack is present, 

within a panel 2 inches wide as indicated by the shaded areas labelled (B) in Figure 10b; 

or 

 that extends beyond the radius area between the horn and the shank as indicated by the 

shaded area labelled (C) in Figure 10c; or 

 that extends 2 inches in length, or in additive length if more than one crack is present, 

within the radius area between the horn and shank as indicated by the shaded areas 

labelled (C) in Figure 10c; or 

 that is present in the unshaded areas of Figure 10a, 10b, and 10c. 

Additionally, inspectors who find couplers having a section broken out within the shaded areas 

labeled (B) or (C) in Figures 10b and 10c, must be removed from service. If couplers have a 

section broken out within the other shaded areas, the inspector should bring this condition to the 

attention of the railroad, as the AAR identifies this condition as cause for removal in their 

Interchange Rules. (MP&E 98-43) 
Federal Railroad Administration 

4 - 30 

Figure 10: Enforcement guidance for the removal of cracked couplers from service 

The regulation is specific in that the coupler knuckle must be broken or cracked on the inside 

pulling face of the knuckle. 

The anti-creep protection should be capable of preventing the unintentional unlocking of the 

coupler lock. A coupler lock lift slightly raised may raise the coupler lock and nullify the anticreep protection of the coupler. When inspection is made for anti-creep, the car should not be in 

draft or buff and should be on level, tangent track. The lack of “rod-eye” clearance does not 

necessarily mean there is no anti-creep protection. 

Figure 10a 

Figure 10b 

Figure 10c 
Motive Power and Equipment Compliance Manual 

4 - 31 

Regulation

§215.125 Defective Uncoupling Device. 

A railroad may not place or continue in service a car, if the car has an uncoupling device without 

sufficient vertical and lateral clearance to prevent- 

(a) Fouling on curves; or 

(b) Unintentional uncoupling. 

Guidance

Toggle clearance should be closely examined. 

Regulation

§215.127 Defective Draft Arrangement. 

A railroad may not place or continue in service a car, if- 

(a) The car has a draft gear that is inoperative; 

(b) The car has a broken yoke; 

(c) An end of car cushioning unit is- 

(1) Leaking clearly formed droplets; or 

(2) Inoperative; 

(d) A vertical coupler pin retainer plate- 

(1) Is missing (except by design); or 

(2) Has a missing fastener; 

(e) The car has a draft key or draft key retainer, that is- 

(1) Inoperative; or 

(2) Missing; or 

(f) The car has a missing or broken follower plate. 

Guidance

Whenever the draft gear unit is not performing its intended function of absorbing shocks and 

impact forces as designed, the unit is defective.

A striker casting that exhibits fresh “batter marks” is generally an indication of a defective draft 

system component. 
Federal Railroad Administration 

4 - 32 

An end-of-car cushioning unit is defective if it is inoperative and not performing its intended 

function of absorbing shocks and impacts, or is leaking clearly formed droplets. A cushioning 

unit should not be considered defective if it is losing only a minute amount of fluid through 

seepage. The primary concern is an excessive loss of fluid that could render the cushioning unit 

inoperative. Therefore, a cushioning unit is defective if it is leaking fluid in clearly formed 

droplets. “Clearly formed droplets” means a fresh accumulation of oil (not dirty or dried) which 

continually forms into beads. 

Based on technical data presented at an MP&E Technical Resolution Committee, FRA has 

determined that cushioning unit pressure indicators are not sufficiently reliable to determine the 

operating status of cushioning units. The unreliability of the indicators is due to the variable buff 

and draft forces exerted on cushioning devices while freight cars are in use in train yards. 

Therefore, FRA inspectors should not rely on cushioning unit pressure indicators to determine 

the operational status of a cushioning device. Thus, if clearly formed droplets are present the 

cushioning unit is defective and must be repaired, regardless of the indication provided by the 

pressure indicator. However, once a freight car is placed on a repair track, the railroad may use 

the pressure indicator to aid in determining the operating status of the cushioning unit. (MP&E 

00-03) 

A unit is defective if the front or rear lugs are broken or missing. 

Of the three return springs, more than one defective spring constitutes a defective condition. 

Inspectors should be aware that some tank cars have sustained a failed stub sill assembly, 

resulting in the train parting and going into emergency. In one case, FRA investigations revealed 

that the head block, which normally is attached by welding to the tank head and stub sill, was not 

attached to the stub sill and was actually “floating” (only attached to the tank head). The top of 

the stub sill assembly showed signs of the head block rubbing. The stub sill failed at the rear of 

the draft gear, completely separated, including the end cross over platform. The broken stub sill 

remained attached to the adjacent car by the top and bottom shelf coupler, which prevented it 

from falling to the track structure. 

There have been similar problems with fabricated stub sill dual diameter tank cars. Some cars 

built between 1962 and 1969 have exhibited minor crack indications in the weld connecting the 

cradle pad to the tank. Those cars with verified cracks revealed that the cracks always initiated 

in the weld attachment to the top cover plate and did not propagate through the top cover plate to 

the sill. 
Motive Power and Equipment Compliance Manual 

4 - 33 

Due to the described experiences, a close inspection is to be made to all tank cars with stub 

sills. The installation should be carefully examined at the stub sill securement for any signs of 

stress. If the inspection of any tank car equipped with stub sills reveals any defect of the stub 

sill, the inspector is to notify the regional MP&E Specialist providing the following information: 

 

Date:____ Railroad________ Shipper_________ Location ________ 

Initial & Car number_________ Built date_______ DOT Spec._______ 

Waybill No. and Date, Commodity_______________ Routing___________ 

Description of defect____________________________________________ 

Action taken by the railroad______________________________________ 

Any other information___________________________________________ 

The MP&E specialist should forward this information to the MP&E Staff Director. 

(MP&E 98-24)

Regulation

§215.129 Defective cushioning device. 

A railroad may not place or continue in service a car if it has a cushioning device that is- 

(a) Broken; 

(b) Inoperative; or 

(c) Missing a partunless its sliding components have been effectively immobilized. 

Guidance

A center of car cushioning unit should not be considered defective if it is losing only a minute 

amount of fluid through seepage. The primary concern is an excessive loss of fluid that could 

render the cushioning unit inoperative. A leaking cushioning unit is defective if it is leaking 

fluid in clearly formed droplets. Note: “Clearly formed droplets” means a fresh accumulation of 

oil (not dirty or dried) which continually and/or slowly forms into beads. If the area is just wet in 

appearance, it should not be taken as a defective condition. 

Regulation

Subpart C-Restricted Equipment 

§215.203 Restricted cars. 

(a) This section restricts the operation of any railroad freight car that is- 

(1) More than 50 years old, measured from the date of original construction; 
Federal Railroad Administration 

4 - 34 

(2) Equipped with any design or type component listed in appendix A to this part; or 

(3) Equipped with a Duryea under-frame constructed before April 1, 1950, except for a 

caboose which is operated as the last car in a train. 

(b) A railroad may not place or continue in service a railroad freight car described in paragraph 

(a) of this section, except under conditions approved by the Federal Railroad Administrator. 

(c) A railroad may petition the Administrator to continue in service a car described in paragraph 

(a) of this section. Each petition shall be: 

(1) Submitted not less than 90 days before the car is to be operated; 

(2) Be submitted in triplicate; and 

(3) State or describe the following: 

(i) The name and principal business address of the petitioning railroad. 

(ii) The name and address of the entity that controls the operation and 

maintenance of the car involved. 

(iii) The number, type, capacity, reporting marks, and car numbers of the cars, 

their condition, status and age measured from the date of original construction. 

(iv) The design, type component, or other item that causes the car to be restricted. 

(v) The maximum load the cars would carry. 

(vi) The maximum speed at which the cars would be operated. 

 (vii) That each car has been examined and found to be safe to operate under the 

conditions set forth in the petition. 

(vii) The territorial limits within which the cars are to be operated and the name 

of each railroad that will receive the cars in interchange. 

Guidance

The inspector should be aware that there are many approvals (some mistakenly call these 

waivers) in place allowing the continued operation of 50-year old cars only in approved 

territorial limits with unique operating conditions. Cars operating over the 50-year limit must be 

stenciled with the letter R, as required in the next subpart.

Regulation

Subpart D-Stenciling 

§215.301 General 

The railroad or private car owner reporting mark, the car number, and built date shall be 

stenciled, or otherwise displayed, in clearly legible letters and numbers not less than seven inches 

high, except those of the built date which shall not be less than one (1)-inch high: 

(a) On each side of each railroad freight car body; and 

(b) In the case of a tank car, in any location that is visible to a person walking at track level 

beside the car. 

§215.303 Stenciling of restricted cars. 
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4 - 35 

(a) Each restricted railroad freight car that is described in §215.205(a) of this part shall be 

stenciled, or marked- 

(1) In clearly legible letters; and 

(2) In accordance with paragraphs (b) and (c) of this section. 

(b) The letter “R” shall be- 

(1) Placed immediately below or to the right of the car number; 

(2) The same color as the reporting mark; and 

(3) The same size as the reporting mark. 

(c) The following terms, to the extent needed to completely indicate the basis for the restricted 

operation of the car, shall be placed on the car following the symbol “R” in letters not less than 

one inch high: 

(1) Age 

(2) Coupler. 

(3) Draft. 

(4) Bearings. 

(5) Truck. 

(6) Under-frame. 

(7) Wheels. 

(8) Yoke. 

§215.305 Stenciling of maintenance-of-way equipment. 

(a) Maintenance-of-way equipment (including self-propelled maintenance-of-way equipment) 

described in §215.3(c)(3) shall be stenciled, or marked- 

(1) In clearly legible letters; and 

(2) In accordance with paragraph (b) of this section. 

(b) The letters “MW” must be- 

(1) At least 2 inches high; and 

 (2) Placed on each side of the car. 

Guidance

Maintenance-of-way (MOW) equipment is equipment owned/operated for railroad maintenance 

purposes and must be stenciled with MW. MOW equipment cannot be used to haul 

commodities which will generate revenue for the railroad. Canadian MOW cars are stenciled 

with RSE (Railway Service Equipment) in lieu of the MW. FRA has granted a waiver to allow 

RSE stencil instead of the MW stencil on MOW cars based out of Canada. 

If vandals have painted graffiti on the car and obscured the identification marks, the inspector 

should point the defect out to the railroad for corrective action, but not issue a violation unless 

these actions become rampant. 
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4 - 36 

Inspectors should ensure that maintenance-of-way equipment is used for maintenance-of-way 

activities, and not used for revenue service. 

Regulation

Appendix D to Part 215 – Pre-Departure Inspection Procedure

At each location where a freight car is placed in a train and a person designated under §215.11 is 

not on duty for the purpose of inspecting freight cars, the freight car shall, as a minimum, be 

inspected for the imminently hazardous conditions listed below that are likely to cause an 

accident or casualty before the train arrives at its destination. These conditions are readily 

discoverable by a train crew member in the course of a customary inspection. 

1. Car body 

(a) Leaning or listing to side. 

(b) Sagging downward. 

(c) Positioned improperly on truck. 

(d) Object dragging below. 

(e) Object extending from side. 

(f) Door insecurely attached. 

(g) Broken or missing safety appliance. 

(h) Lading leaking from a placarded hazardous material car. 

2. Insecure coupling. 

3. Overheated wheel or journal. 

4. Broken or extensively cracked wheel. 

5. Brake that fails to release. 

6. Any other apparent safety hazard likely to cause an accident or casualty before the train 

arrives at its destination. 

Guidance

 

There have been instances of pre-departure mechanical inspections being conducted improperly. 

FRA is particularly concerned about the practice of conducting pre-departure inspections 

pursuant to Appendix D of Part 215, while the equipment is moving (i.e., a “roll by” inspection) 

or by conducting such inspections from locomotives on an adjacent track. While regulations do 

not specify the physical actions necessary to conduct a proper inspection, FRA believes such 

inspections require that inspectors position themselves in such a manner that all of the required 

observations can be safely made. 
Motive Power and Equipment Compliance Manual 

4 - 37 

Such observations cannot be safely made while equipment is moving or when the inspector is 

positioned on a locomotive on an adjacent track. While some of the individual conditions may 

be observable while a train is moving, others are not, and a person cannot reasonably be expected 

to see all of them as a train is rolling by. 

FRA inspectors should strongly consider issuing violations whenever they observe the above 

inspection practices being performed instead of a proper Appendix D inspection. In appropriate 

circumstances, the inspector may assess a civil penalty for each car in a train that does not 

receive the proper pre-departure mechanical inspection. These violations should be treated as 

violations separate and distinct from and in addition to any substantive violation conditions 

found on individual cars. (MP&E 98-58)

The regulations allow for a car to go to destination on an Appendix D inspection. 

A person performing an Appendix D inspection cannot make the determination for movement 

under §215.9. However, if a train crew member is listed as a designated inspector, he or she can 

make the determination for movement under §215.9, but would be required to perform a full 

inspection for compliance with this Part, not an Appendix D inspection. 
 

 

5 - 1 

Chapter 5 

Blue Signal Protection of Workmen, Part 218 

 

Introduction

The minimum requirements for Blue Signal Protection of Workmen are prescribed in 49 CFR 

Part 218, Subpart B. An example of a blue signal sign is shown in Figure 1. This Subpart B 

requires railroads to take certain measures to protect their employees when engaged in 

inspection, testing, repair, and servicing of rolling equipment. It is designed to reduce the 

number of serious accidents resulting from human factors. A railroad may prescribe additional 

and/or more stringent requirements than those found in this regulation. 

On the following pages, you will find the sections of the regulation that have interpretive 

guidance and related information to aid the inspector in the performance of blue signal 

inspections. After each section of the regulation is an interpretation or policy as established by 

FRA. 

 

Figure 1: Blue signal sign attached to snow-covered track in a 

train yard 
Federal Railroad Administration 

5 - 2

Reports of blue signal inspections are to be made on the Inspection Report, F6180.96. Violations 

are to be submitted on Form F6180.67. 

On some occasions, it may be necessary to devote a major portion of the inspection day to 

conducting blue signal observations; however, in most instances, inspectors should incorporate 

blue signal inspections with their routine inspection activities. For example, during a locomotive 

inspection at a locomotive repair facility, observations of that facility’s blue signal protection 

would be appropriate. 

Before conducting any blue signal inspections, you will need knowledge of any permissible 

alternative methods of providing the required protection. For instance, using the above example, 

it is the railroad’s option whether to use the procedures listed in § 218.27 or in § 218.29 to 

protect a locomotive servicing track area. Before entering a particular location, you must also be 

aware of any waivers of the regulations applicable to that location. 

Remember, it is the railroad’s obligation to provide blue signal protection. Inspectors shall not 

order railroad personnel to stop working, nor should the inspector establish blue signal 

protection. It is the inspector’s responsibility to monitor and determine whether blue signal 

protection is being applied correctly. If it is not being applied correctly, the inspector must take 

appropriate enforcement action to correct the situation. Noncompliance with blue signal 

regulations is serious and can lead to injury or death.

Part 218 – Subpart A, General

218.1 Purpose. 

This part prescribes minimum requirements for railroad operating rules and practices. Each 

railroad may prescribe additional or more stringent requirements in its operating rules, 

timetables, timetable special instructions, and other special instructions. 

218.3 Application. 

(a) Except as provided in paragraph (b) of this section, this part applies to railroads that operate 

rolling equipment on standard gage track which is part of the general railroad system of 

transportation. 

(b) This part does not apply to -- 

(1) A railroad that operates only on track inside an installation which is not part of the 

general railroad system of transportation, or 

(2) Rapid transit operations in an urban area that are not connected with the general 

railroad system of transportation. 

Guidance 
 Motive Power and Equipment Compliance Manual 

5 - 3

Blue signal regulations apply only to railroads that operate rolling equipment on standard gage 

track that is part of the general railroad system of transportation. It does not apply to a railroad 

that operates only on tracks inside an installation that is not part of the general railroad system, or 

a railroad that operates only on tracks used exclusively for urban rapid transit. However, if a 

railroad employee is working on, under, or between rolling equipment on a track located inside 

an industry or plant served by a railroad, blue signal protection must be established. It does not 

apply to contractors, even if they are working on rolling equipment on standard gage track that is 

part of the general railroad system of transportation. 

218.5 Definitions. 

Absolute block means a block in which no train is permitted to enter while it is occupied by 

another train. 

Blue signal means a clearly distinguishable blue flag or blue light by day and a blue light at 

night. When attached to the operating controls of a locomotive, it need not be lighted if the inside 

of the cab area of the locomotive is sufficiently lighted so as to make the blue signal clearly 

distinguishable. 

Camp car means any on-track vehicle, including outfit, camp, or bunk cars or modular homes 

mounted on flat cars used to house rail employees. It does not include wreck trains. 

Car shop repair track area means one or more tracks within an area in which the testing, 

servicing, repair, inspection, or rebuilding of railroad rolling equipment is under the exclusive 

control of mechanical department personnel. 

Controlling locomotive means a locomotive arranged as having the only controls over all 

electrical, mechanical and pneumatic functions for one or more locomotives, including controls 

transmitted by radio signals if so equipped. It does not include two or more locomotives coupled 

in multiple which can be moved from more than one set of locomotive controls. 

Designated crew member means an individual designated under the railroad’s operating rules as 

the point of contact between a train or yard crew and a utility employee working with that crew. 

Effective locking device when used in relation to a manually operated switch or a derail means 

one which is: 

 (1) Vandal resistant; 

 (2) Tamper resistant; and 

(3) Capable of being locked and unlocked only by the class, craft or group of employees 

for whom the protection is being provided. 

Group of workers means two or more workers of the same or different crafts assigned to work 

together as a unit under a common authority and who are in communication with each other 

while the work is being done. 
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5 - 4

Locomotive means a self-propelled unit of equipment designed for moving other railroad rolling 

equipment in revenue service including a self-propelled unit designed to carry freight or 

passenger traffic, or both, and may consist of one or more units operated from a single control. 

Locomotive servicing track area means one or more tracks, within an area in which the testing, 

servicing, repair, inspection, or rebuilding of locomotives is under the exclusive control of 

mechanical department personnel. 

Main track means a track, other than an auxiliary track, extending through yards or between 

stations, upon which trains are operated by timetable or train order or both, or the use of which is 

governed by a signal system. 

Rolling equipment includes locomotives, railroad cars, and one or more locomotives coupled to 

one or more cars. 

Switch providing access means a switch which if traversed by rolling equipment could permit 

that rolling equipment to couple to the equipment being protected. 

Train or yard crew means one or more railroad employees assigned a controlling locomotive, 

under the charge and control of one crew member; called to perform service covered by Section 

2 of the Hours of Service Act; involved with the train or yard movement of railroad rolling 

equipment they are to work with as an operating crew; reporting and working together as a unit 

that remains in close contact if more than one employee; and subject to the railroad operating 

rules and program of operational tests and inspections required in §§217.9 and 217.11 of this 

chapter. 

Utility employee means a railroad employee assigned to and functioning as a temporary member 

of a train or yard crew whose primary function is to assist the train or yard crew in the assembly, 

disassembly or classification of rail cars, or operation of trains (subject to the conditions set forth 

in §218.22 of this chapter). 

Worker means any railroad employee assigned to inspect, test, repair, or service railroad rolling 

equipment, or their components, including brake systems. Members of train and yard crews are 

excluded except when assigned such work on railroad rolling equipment that is not part of the 

train or yard movement they have been called to operate (or been assigned to as “utility 

employees”). Utility employees assigned to and functioning as temporary members of a specific 

train or yard crew (subject to the conditions set forth in §218.22 of this chapter), are excluded 

only when so assigned and functioning. 

Note: Servicing does not include supplying cabooses, locomotives, or passenger cars with items 

such as ice, drinking water, tools, sanitary supplies, stationery, or flagging equipment. Testing 

does not include (i) visual observations made by an employee positioned on or alongside a 

caboose, locomotive, or passenger car; or (ii) marker inspections made in accordance with the 

provisions of §221.16(b) of this chapter. 

Guidance 
 Motive Power and Equipment Compliance Manual 

5 - 5

Blue signal means a clearly distinguishable blue flag, blue sign, or blue light. The effectiveness 

of the blue signal is dependent upon the device being clearly distinguishable to the operator in 

control of the movement of rolling equipment; therefore, compliance must be evaluated with this 

in mind. A badly deteriorated blue signal or one that is covered with oil or dirt, cannot be 

considered to be in compliance. A blue light with a weak battery, broken lens, and/or a blue 

signal which is obviously inadequate in size or intensity and cannot be clearly distinguishable, is 

not in compliance with the requirements of the regulation. A blue signal used at night must be 

illuminated, unless an unlighted device is attached to the controls of a locomotive and the cab of 

the locomotive is adequately lighted so as to make the blue signal clearly distinguishable. The 

law allows a blue light to be used by day, but the inspector should determine that it is clearly 

distinguishable by either its size or intensity. Inspectors should also consider the intensity of 

lights at night. If a floodlight washes out the effectiveness of a blue light, an exception should be 

taken. Small lights that are designed to be used in the cab of a locomotive should not be used in 

the gage of the track unless the intensity of the light makes it clearly distinguishable to the 

operator in control of rolling equipment. 

Car shop repair track area means one or more tracks within an area in which the testing, 

servicing, repair, inspection, or rebuilding of railroad rolling equipment is under the exclusive 

control of the mechanical department personnel. It includes heavy repair tracks located within 

buildings, as well as tracks where total erecting or rebuilding of the rolling equipment occurs. 

Controlling Locomotive means the locomotive that is controlling from its cab the propulsion 

system, sanders, and power brake system of each locomotive that is pneumatically, electrically, 

and mechanically connected together in a consist. “Electrically” can be either by a jumper cable 

or by a radio signal. “Mechanically” means that the locomotive units are physically coupled 

together. “Pneumatically” means the appropriate air hoses that control the operation of the 

brakes are connected and cut in. 

Effective locking device means a device that can be locked and unlocked only by the class, craft, 

or group of workmen performing work on the rolling equipment. It must be of substantial 

construction or technically designed so that it is vandal-resistant and tamper-resistant. A rail 

clamp or switch point blocking device that cannot be locked does not comply with the 

requirements of this regulation. Train and yard crews should not be able to unlock switches or 

derails protecting workmen, unless they are the group of workers performing work or tasks that 

requires blue signal protection. If train or yard crews need to apply blue signal protection, a 

standard operating department switch lock will not satisfy the requirements of this regulation. 

An “other than standard” switch lock can be used, as long as other train and yard crews cannot 

unlock it. A remotely controlled switch must have a plug, key, or cover properly applied to the 

control panel which immobilizes the switch control lever that is being secured to establish 

protection. It must be applied in such a manner that the control lever cannot be thrown for the 

route into the protected track without first removing the device. A written tag alone, attached to 

the button or lever, does not comply. Any remotely controlled switch that can be overridden in 

the field by use of a manual lever, without establishing prior authority and taking that switch out 

of power, must to be treated as a manual switch and effectively locked in the field. Inspectors 

should physically examine and test the locking device to ensure the lock functions as intended. 
Federal Railroad Administration 

5 - 6

Group of workers means two or more workers from the same or different crafts that are assigned 

to work together as unit or group under a common authority (such as a lead man, roundhouse 

foreman, or car shop foreman) and all members of the group are in some form of communication 

with each other while the work is being performed. 

Locomotive means a self-propelled, on-track piece of equipment designed for moving revenue 

freight and passenger cars over the railroad. It may be a traditional locomotive powered by 

electricity, diesel-electric, turbine, or steam. It could also be in the form of a self-propelled hirail vehicle used in revenue service. Based upon the definition as written for this regulation, an 

MU car would be a locomotive, but a control-cab of a suburban push-pull passenger train 

operation would not, unless a locomotive were attached to it and the controls of the control-cab 

were cut in. Blue signal protection for remote controlled locomotives is handled in the same 

manner as a traditional locomotive. 

What is required to establish blue signal protection for remote controlled locomotives? 

Place the locomotive into manual operation and establish blue signal protection as if it 

were a regular locomotive. 

Locomotive servicing track area means one or more tracks within an area that is under exclusive 

control of mechanical department personnel. It includes tracks known as the “back shops” and 

tracks within the area that are located inside of buildings where major overhauling or rebuilding 

of locomotives occurs. Access to, from, and within the protected area would have to come from 

the mechanical department personnel in charge of that area. 

Main track has been used in railroad operating rule books for many years and should have a 

common meaning throughout the industry to the extent that there should be no mistaking it from 

tracks commonly known by such other defined terms as “yard tracks” or “siding” in judging 

compliance with this regulation. The fact that the authority for movement on a track is Rule 93, 

“Yard limits” rule, has no bearing on this interpretation. Therefore, any track that does not meet 

the definition of a main track is other than a main track. 

Rolling equipment refers to locomotives or railroad cars, or any combination of such.. It is not 

meant to include, for the purposes of this regulation, maintenance-of-way on-track equipment 

that is protected by other means. Also, derailment situations do not require blue signal 

protection. 

Switch providing access: When protected equipment is standing on an entrance switch so as to 

prevent other equipment from entering the track through that switch, it ceases to be an access 

switch. However, once the switch becomes exposed so as to permit other equipment to enter the 

protected track and couple to the protected cars, it becomes a switch providing access. 

Train or yard crew: Train or yard crew members are permitted to work on, under, or between 

any railroad rolling equipment they are called to operate, without establishing blue signal 

protection. Note: The train and yard crew exclusion only applies to the equipment they are 

called to operate. They cannot assist another crew, unless blue signal protection is established 

(if the task warrants blue signal protection) or the entire crew (including the locomotive) is 
 Motive Power and Equipment Compliance Manual 

5 - 7

involved assisting another crew, provided that both crews are in communication with each other 

and are aware of the movements to be made. 

Can a train crewmember perform a mechanical repair (change a brake shoe) without 

establishing blue signal protection? 

YES, if the repairs are performed on the equipment the crew member is called to operate 

and if the crew member is not working as a utility employee.

Can members of one crew assist another crew, such as making a coupling at a road crossing, 

replacing or changing EOT batteries, or changing a brake hose without establishing blue 

signal protection? 

NO - It would have to involve the entire crew, to include using the locomotive, to 

handle the equipment and assist the other crew. If only a few crewmembers assist 

the other crew, then blue signal protection must be established.

Utility Employee (UE) is not restricted to any particular craft or job title. The UE may be any 

railroad employee, provided that all of the prerequisites contained in § 218.22(a) are met. 

Worker means railroad employees assigned to inspect, test, repair, or service railroad rolling 

equipment and their components, including brake systems. Train and yard crews are excluded, 

except when assigned to perform such work on railroad rolling equipment that is not part of the 

train or yard movement they have been called to operate. The train and yard crewmember 

exclusion is based on the rationale that the crew members working together as an operating crew, 

with their assigned locomotive engineer at the controls of the locomotive, would have complete 

control over the movement of any rolling equipment on which they are working. 

Railroad security forces or clerical personnel who board railroad cars for the purpose of checking 

lading for pilferage or vandalism, or store house employees loading or unloading cars (even 

when using a forklift) are not considered to be workers as defined in this part because they are 

not assigned to inspect, test, repair, or service the railroad rolling equipment. Therefore, blue 

signal protection is not required under the regulation. Fueling and sanding locomotives does not 

require blue signal protection, provided the tasks do not require the individual to go on, under, or 

between the locomotive. 

The law only applies to “railroad workers.” The term railroad worker means an employee who 

is employed and paid directly by the railroad. Non-railroad employees (contractors, suppliers, 

etc.) are not required to use blue signal protection under Federal regulations. Although many 

railroads require these individuals to comply with blue signal regulations as part of the 

conditions of their contracts, FRA cannot enforce the contractor’s use of blue signal protection. 

However, an inspector should advise the railroad of noncompliance when it is known that the 

railroad expects the contractors to comply. 

Servicing, as noted in the footnote under this definition, does not include supplying cabooses, 

locomotives, or passenger cars with such items as ice, drinking water, tools, sanitary supplies, 

stationery, or flagging equipment. 
Federal Railroad Administration 

5 - 8

Testing does not include visual observations made by an employee positioned inside or alongside 

a caboose, locomotive, or passenger car. A worker involved in these specific work activities is 

not deemed to be in a hazardous position should the equipment inadvertently move. 

Part 218 – Subpart B, Blue Signal Protection of Workers. 

218.21 Scope. 

This Subpart prescribes minimum requirements for the protection of railroad employees engaged 

in the inspection, testing, repair, and servicing of rolling equipment whose activities require them 

to work on, under, or between such equipment and subjects them to the danger of personal injury 

posed by any movement of such equipment. 

Guidance 

Initially, the rationale in developing the language of this subsection was that these general work 

categories (inspecting, testing, repair, and servicing) usually require an employee to go on, 

under, or between rolling equipment. In so doing, the employee would be in close proximity to 

the equipment, where he or she would be vulnerable to the possibility of a serious personal injury 

if an unexpected movement of the equipment were to occur. However, in identifying those 

general work activities and positions in relation to railroad rolling equipment in such broad 

terms, it was inevitable that they would encompass a number of specific jobs which definitely do 

not expose the worker to personal injury. FRA realized the predicament, and revised the 

language in 1979 by inserting the word “and” in the regulatory language - 

“...and subjects them to the danger of personal injury...” 

Therefore, it is not solely the work being done (inspecting, testing, repairing, or servicing) and 

where the employee is positioned in relation to the equipment (on, under, or between), but also 

whether this causes the employee to be placed in a potentially hazardous position. 

Generally, non-hazardous work will be combined with work that is hazardous, and blue signal 

protection is required. However, there may be times when certain non-hazardous work can be 

isolated in such a manner that blue signal protection would not be required. For example, 

equipment inspections that can be made by an employee from a position on the ground alongside 

the equipment does not represent a hazardous situation. Seated at the controlling locomotive and 

manipulating the air brake handles or throttle or setting the MU valve on the control stand does 

not represent a hazardous situation. Testing of an air brake system, when purely visual in nature 

and requires an employee to observe the position of air brake piston while standing on the 

ground beside the cars, is another example of a non-hazardous situation that would not require 

blue signal protection. If the employee has to go under the equipment to observe the piston 

travel, as with many truck-mounted brake systems, blue signal protection is required. A Part 215 

pre-departure inspection would require blue signal protection, because the individual making the 

inspection would have to go under and between the equipment to properly conduct the 

inspection. A train crew making an Appendix D inspection would not have to establish blue 

signal protection if it is the equipment they are called to operate. 
 Motive Power and Equipment Compliance Manual 

5 - 9

When conducting a purely visual inspection of a locomotive, as long as the employee does not 

go under the locomotive, step into the engine compartment, or go onto the roof of the 

locomotive, the employee would not be in a hazardous situation. For example, gaging wheels 

would require blue signal protection because the individual would be under the equipment. An 

employee could open engine compartment doors and look inside to inspect for oil or water leaks, 

exhaust leaks, check the cooling water sight glass, and check engine oil as long as the employee 

does not physically step inside the engine compartment and does not do anything beyond visual 

checks—all without establishing blue signal protection. If the locomotive engineer is conducting 

the inspection on locomotives he or she is called to operate, no blue signal protection is required. 

Certain servicing activities can be carried out without exposure to danger. Examples of such 

activities would be: 

 Bleeding of the air brake system on cars, oiling journal boxes, passenger coach interior 

and exterior cleaning not requiring the use of ladders. 

 Evacuating and recharging passenger car soil holding tanks. 

 Supplying passenger cars with water or supplying locomotives with water and fuel by 

attaching a hose to an exterior outlet. 

 Changing radios and HTDs on locomotives that use quick disconnect fittings and do not 

require the use of tools. 

 In instances where sanding a locomotive can be accomplished by attaching the sanding 

hose to a side filler cap without physically going on the locomotive. 

Similarly, certain supplying activities such as supplying locomotives and cabooses with ice, 

water, fuses, stationery and paper toweling can be carried out without exposure to danger. These 

and similar activities, when effectively confined to the specific non-hazardous work function, do 

not require blue signal protection. 

There are certain activities that definitely call for the display of blue signals. Examples of such 

activities (when performed by non-train or non-yard crew members) are: 

 Breaking or making air hose connections. 

 Connecting or disconnecting electric control cables between equipment. 

 Installing/removing/servicing/repair of rear end devices (markers and telemetry units). 

 Any air brake test requiring an employee to go under or between rolling equipment. 

 Replacing broken windows. 

 Changing brake shoes. 

 Activities that require the use of a ladder. 

 Performing electrical repairs that involve work partially or wholly within the confines of 

an electrical cabinet. 

 Inspecting the undercarriage from a pit. 

 Repairing and closing doors on a car if tools are required. 

All these and certain other activities do cause the workers to position themselves in such a way 

that they are vulnerable to personal injury if unexpected movement of the equipment occurred. 
Federal Railroad Administration 

5 - 10

In the event a worker has to position himself or herself between the rails at the end of a car, as 

when changing a knuckle or air hose, blue signal protection is required. When repairs require the 

worker to be on, under, or between rolling equipment, then blue signals unquestionably are 

required. It is the function or nature of the work being performed that determines the protective 

provisions of the rule, not the craft or title of the employee. 

The blue signal regulation does not apply to derailment situations. Assuring protection for 

workers involved in such operations is the responsibility of the individual railroad in accordance 

with its own operating rules. Such operations are usually well coordinated, controlled operations 

under the direction of a wreck master and/or transportation supervisor at the scene. Requiring 

blue signals under these circumstances would unreasonably hamper re-railing operations. Unlike 

routine operations, all personnel involved in this type of work are aware of the special conditions 

that exist and are familiar with the necessary precautions to take when equipment moves take 

place. 

Mechanized track maintenance operations do not require blue signal protection, as these 

operations are addressed by railroad operating rules and other regulations. Under railroad 

operating rules, flags of another color have been designated for this purpose, and those rules 

specify the exact manner in which they are to be displayed to provide protection for such 

operations. 

Taking a track “out of service” does not provide relief to this regulation. Blue signal protection 

would have to be established on out-of-service tracks if the work being performed requires it. 

§218.22 Utility employee.

(a) A utility employee shall be subject to the Hours of Service Act, and the requirements for 

training and testing, control of alcohol and drug use, and hours of service record keeping 

provided for in parts 217, 219, and 228 of this chapter. 

(b) A utility employee shall perform service as a member of only one train or yard crew at any 

given time. Service with more than one crew may be sequential, but not concurrent. 

(c) A utility employee may be assigned to and serve as a member of a train or yard crew without 

the protection otherwise required by Subpart D of part 218 of this chapter only under the 

following conditions: 

(1) The train or yard crew is assigned a controlling locomotive that is under the actual 

control of the assigned locomotive engineer of that crew; 

(2) The locomotive engineer is in the cab of the controlling locomotive, or, while the 

locomotive is stationary be replaced in the cab by another member of the same crew; 

(3) The utility employee established communication with the crew by contacting the 

designated crew member on arriving at the train (as defined for the purpose of this 

section as one or more locomotives coupled, with or without cars) and before 

commencing any duties with the crew. 
 Motive Power and Equipment Compliance Manual 

5 - 11

(4) Before each utility employee commences duties, the designated crew member shall 

provide notice to each crew member of the presence and identity of the utility employee. 

Once all crew members have acknowledged this notice, the designated crew member 

shall advise the utility employee that he or she is authorized to work as part of the crew. 

Thereafter, communication shall be maintained in such a manner that each member of the 

train or yard crew understands the duties to be performed and whether those duties will 

cause any crew member to go on, under, or between the rolling equipment; and 

(5) The utility employee is performing one or more of the following functions: set or 

release hand brakes; couple or uncouple air hoses and other electrical or mechanical 

connections; prepare rail cars for coupling; set wheel blocks or wheel chains; conduct air 

brake tests to include cutting air brake components in or out and position retaining 

valves; inspect, test, install, remove or replace a rear end marking device or end of train 

device. Under all other circumstances a utility employee working on, under, or between 

railroad rolling equipment must be provided with blue signal protection in accordance 

with §§218.23 through 218.30 of this part. 

(d) When the utility employee has ceased all work in connection with that train and is no longer 

on, under, or between the equipment, the utility employee shall notify the designated crew 

member. The designated crew member shall then provide notice to each crew member that the 

utility employee is being released from the crew. Once each crew member has acknowledged the 

notice, the designated crew member shall then notify the utility employee that he is released from 

the train or yard crew. 

(e) Communications required by §218.22(c)(4) and (d) shall be conducted between the utility 

employee and the designated crew member. This communications shall be conducted either 

through direct verbal contact, by radio in compliance with part 220 of this chapter, or by oral 

telecommunication of equivalent integrity. 

(f) No more than three (3) utility employees may be attached to one train or yard crew at any 

given time. 

(g) Any railroad employee who is not assigned to a train or yard crew, or authorized to work 

with a crew under the conditions set forth by paragraph (b) of this section, is a worker required to 

be provided blue signal protection in accordance with §§218.23 through 218.30 of this part. 

(h) Nothing in this section shall affect the alternative form of protection specified in §221.16 of 

this chapter with respect to inspection of rear end marking devices. 

Guidance

When an individual is working as a utility employee (UE), he or she is working as a temporary 

member of a specific train or yard crew. This allows the UE to be excluded from the blue signal 

protection requirements only when performing the tasks listed in § 218.22(c)(5). Under all other 

circumstances, a UE working on, under, or between rolling equipment must be provided with 

blue signal protection. 
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5 - 12

As defined in § 218.5, the UE is not restricted to any particular craft or job title. The UE may be 

any “railroad” employee, provided that the prerequisites contained in § 218.22(a) are met, 

namely that the UE is subject to: (1) the railroad’s operating rules, (2) the hours of service laws, 

and (3) Federal drug and alcohol regulations. If the UE is a mechanical department employee 

(carman, machinist, etc.), an abbreviated version of the instructions for operating rules can be 

given to satisfy the requirements of Part 217. 

The regulation limits the assignment of the UE to only one crew at a time. This is necessary to 

prevent confusion as to the location and duties of that employee, and to ensure that the employee 

is, in fact, a member of the crew to which he or she is assigned for the duration of the 

assignment. 

A train or yard crew member cannot become a UE and work with another train or yard crew, 

unless the train or yard crew he or she originally started with has completed its tour of duty or 

has been reconstituted as a new assignment. 

When conducting inspections for compliance regarding the use of UEs, the inspector should 

monitor the following: 

 Communication between the UEs and ranking crew member. UEs and crew members 

must follow the required operating procedures when attaching to and/or detaching from 

the crew. Was the communication made face-to-face, by radio, telephone, or by some 

other form of communication? 

 Presence of locomotive engineer or other crew member in the control compartment or at 

the controls of the controlling locomotive when the UE performs duties on the rolling 

equipment assigned to that train or yard crew. 

 Nature of the work performed by the UE. Ensure the employee does not perform duties 

other than those listed in the regulation that require blue signal protection. There are no 

restrictions on tasks the UE can perform with the crew that do not require blue signal 

protection. 

 No more than three UEs can be assigned to a train or yard crew at the same time. 

 UEs are not assigned to or working with more than one train or yard crew at a time. 

 Inspection of the UE’s hours of service records. 

 The UE has to be in the general vicinity of the crew. The UE cannot be working at a 

remote site without the locomotive and the rest of the crew nearby. 

Regulation

§218.23 Blue signal display. 
 Motive Power and Equipment Compliance Manual 

5 - 13

(a) Blue signals displayed in accordance with §218.25, 218.27, or 218.29 signify that workers are 

on, under, or between rolling equipment. When so displayed -- 

 (1) The equipment may not be coupled to; 

(2) The equipment may not be moved, except as provided for in §218.29; 

(3) Other rolling equipment may not be placed on the same track so as to reduce or block 

the view of a blue signal, except as provided for in §218.29 (a), (b) and (c); and 

(4) Rolling equipment may not pass a displayed blue signal. 

(b) Blue signals must be displayed in accordance with §218.25, 218.27, or 218.29 by each craft 

or group of workers prior to their going on, under, or between rolling equipment and may only 

be removed by the same craft or group that displayed them. 

 

Guidance 

The regulation states that blue signals may only be removed by the same craft or group that 

displayed them. It need not be the same individual, just the same craft or group. If a particular 

worker is not a part of a group, as indicated by the regulation’s definition of “group of workers”, 

then the individual would have to display his or her own blue signal. If a railroad chooses to 

adopt the policy of having different crafts or groups attach an individual disc to a common blue 

signal and having the last worker removing his disc also remove the common blue signal, that 

practice would comply with the the regulation. 

Can a supervisor remove a blue signal if the worker forgot to remove the blue signal and has 

gone home? A supervisor can remove a blue signal displayed, but only if it is known that 

workers are not on, under, or between rolling equipment and are clear of the protected 

equipment, and if he or she is the supervisor of the same craft or group of workers.

The use of blue signals and derails by industries served by railroads as called for under 

Department of Labor, Occupational Safety and Health Administration (OSHA) and hazardous 

materials regulations for the protection of industry employees involved in the loading and 

unloading of railroad cars, is not part of Subpart B - Blue Signal Protection for Workmen. 

However, once a blue signal is displayed on tracks or on rolling equipment, regardless under 

whose authority that signal is displayed, railroad employees must respect the signal as though it 

was displayed in accordance with the requirements of this regulation. Blue signals displayed by 

industry employees must not be removed by railroad employees. Also, when a railroad 

employee is working on, under or between rolling equipment inside an industry or plant served 

by a railroad, blue signal protection must be established. 

A blue signal displayed at or near a manually operated switch providing access to the track must 

be displayed no farther into the track than the fouling (clearance point) of that entrance switch. 

Once the blue signal is properly displayed, there can be NO movement of the equipment, except 

as provided for in § 218.29. 
Federal Railroad Administration 

5 - 14

Regulation

§218.24 One-person crew. 

Guidance

Per §218.24, the one-person crew provision, was suspended effective May 15, 1995. Railroads 

are not required to comply with any part of this section. During the stay, until a revised rule is 

issued, FRA’s policy regarding single person crews (i.e., locomotive engineer working alone, 

such as in hostler or in helper service) is as follows: 

While working on, under, or between equipment they are called to operate, no blue signal 

protection is required for single person crews. However, if a single person RCO crew does not 

have the OCB in his or her possession when going on, under, or between equipment, or if for any 

other reason he or she no longer has control of the equipment he or she was called to operate per 

the definition of a “train or yard crew” member at 218.5, blue signal protection would be 

required for the single person crew. 

Regulation

§218.25 Workers on a main track. 

When workers are on, under, or between rolling equipment on a main track: 

(a) A blue signal must be displayed at each end of the rolling equipment; and 

(b) If the rolling equipment to be protected includes one or more locomotives, a blue signal must 

be attached to the controlling locomotive at a location where it is readily visible to the 

engineman or operator at the controls of that locomotive. 

(c) When emergency repair work is to be done on, under, or between a locomotive or one or 

more cars coupled to a locomotive, and blue signals are not available, the engineman or operator 

must be notified and effective measures must be taken to protect the workers making the repairs. 

Guidance

The important thing to realize when observing blue signal protection on a main track is that the 

regulation does not require lined and locked switches, or the application of derails. However, 

blue signals must be displayed at each end of the rolling equipment to be protected. Ends of the 

equipment refers to placement of a blue flag or blue light in the knuckle or on the coupler of the 

car or locomotive. The inspector should check to see if this has been done with an appropriate 

blue signal. (See “blue signal” definition.) The blue signal displayed at each end of the rolling 

equipment may be attached to the ends of the equipment or it may be displayed on the track 

ahead and behind the equipment in such a manner that there is no doubt about the track and/or 

equipment to which it applies. If one or more locomotives are among the protected equipment, 

then a blue signal must also be attached to the controlling locomotive at a location where it is 

readily visible to someone seated at the controls of that locomotive. The inspector should 
 Motive Power and Equipment Compliance Manual 

5 - 15

evaluate how visible and obvious the blue signal is to someone seated at the controls of the 

locomotive. This requirement is in addition to the blue signals displayed at each end of the 

equipment. The signal should be placed so that the operator does not have to look for it. A 

clamp hanging from the window sill with the blue signal positioned low on the car body of the 

locomotive would not comply. In other words, the signal must be immediately visible to the 

operator without any effort on his part. The absence of a blue signal at any one of the required 

locations (ahead, behind, and/or on the controlling locomotive) means that the equipment is 

unprotected and other than the assigned train crew, employees may not work on, under, or 

between that equipment. 

Remotely controlled switches cannot be used to fulfill the requirements of § 218.25(a)-(b) to 

provide protection on “main track”, as § 218.30 “Remotely controlled switches” references only 

§ 218.27 “Other than main track.” While it is permissible for remotely controlled switches to be 

lined and locked against movement to the main track by a control operator or dispatcher in order 

to provide additional protection during a situation requiring blue signal protection on a main 

track, such action does not fulfill the requirements of 218.25. 

Normally, there are very few locations that routinely perform work requiring blue signal 

protection on a main track. An exception to this is when a railroad maintains fuel and servicing 

facility on a main line for through trains. At a location such as this, first determine if any work is 

being done that requires blue signal protection. Remember that there are certain exceptions to 

what constitutes servicing and testing, and fueling is considered one of these exceptions. A fuel 

hose stretched over a track does not require blue signal protection. 

The emergency provisions were intended to allow railroads flexibility when a train is stopped on 

the main track under emergency circumstances. Under these conditions, the provision can be 

used when blue signals are not available, provided that the train and engine crew has full control 

over train movement. The provisions were not intended to be used for convenience or simply 

because the carrier neglected to maintain a sufficient supply of blue signals for normal use by the 

mechanical personnel. The “emergency provision” provides an alternative means of providing 

protection for workers whenever a train is stopped under emergency circumstances and blue 

signals are not available. This provision does not apply to a train that has any portion of its 

consist in a yard, unless there are no mechanical department employees working in the yard and 

there are no blue signals available. 

When “emergency” repair work is to be done on, under, or between a locomotive and/or one or 

more cars coupled to a locomotive, and blue signals are not available, the locomotive engineer or 

an operator at the controls of the controlling locomotive must be notified and effective measures 

must be taken to protect the workers making the repairs. The emergency must occur when the 

train movement is being controlled by the assigned train crew. A mechanical department 

employee assigned to accompany a train between terminals to monitor the performance of the 

equipment or accompany a dimensional load can use the emergency provision as long as a train 

crew member is at the controls of the locomotive. 

Regulation

§218.27 Workers on track other than main track. 
Federal Railroad Administration 

5 - 16

When workers are on, under, or between rolling equipment on track other than main track – 

(a) A blue signal must be displayed at or near each manually operated switch providing access to 

that track; 

(b) Each manually operated switch providing access to the track on which the equipment is 

located must be lined against movement to that track and locked with an effective locking 

device; and 

(c) The person in charge of the workers1 must have notified the operator of any remotely 

controlled switch that work is to be performed and have been informed by the operator that each 

remotely controlled switch providing access to the track on which the equipment is located has 

been lined against movement to that track and locked as prescribed in §218.30. 

(d) If rolling equipment requiring blue signal protection as provided for in this section is on a 

track equipped with one or more crossovers, both switches of each crossover must be lined 

against movement through the crossover toward that rolling equipment, and the switch of each 

crossover that provides access to the rolling equipment must be protected in accordance with the 

provisions of paragraphs (a) and (b), or (c) of this section. 

(e) If the rolling equipment to be protected includes one or more locomotives, a blue signal must 

be attached to the controlling locomotive at a location where it is readily visible to the 

engineman or operator at the controls of that locomotive. 

Guidance

This is the type of blue signal protection used in train yards and sidings. It can also be used in a 

locomotive service track area or car shop repair area. 

An appropriate blue signal (see “blue signal” definition) displayed at or near a manually operated 

switch providing access to the track must be displayed no farther into the track than the fouling 

point of that entrance switch. If a car or locomotive is positioned almost to the fouling point of 

the entrance switch, the blue signal display can be attached to the ends of the rolling equipment. 

Either way, the blue signal must be displayed in such a manner that there is no doubt about the 

track and/or equipment to which it applies. However, if a derail is used, the blue signal must be 

displayed at each derail. See 49 C.F.R. § 218.29(c). The absence of a blue signal at any of the 

manually operated switches providing access to a track renders the track unprotected and 

workers cannot work on, under, or between equipment on that track. The absence of the blue 

signal at a derail also renders the track unprotected. Similarly, any unlocked derail, or manual or 

remotely controlled switch providing access to the track on which equipment is standing means 

that the equipment on the track is unprotected and workers cannot work on, under, or between 

that equipment. 

 

1 See FRA’s letter of clarification to CSX Transportation at Willard Yard, Ohio, dated May 18, 2009, at the end of 

this section.
 Motive Power and Equipment Compliance Manual 

5 - 17

Rolling equipment may not enter or depart a protected track. Exception: Only after all work 

activity has ceased, and the workers have been notified to stand clear and the blue signal 

protection has been removed from the switch through which the equipment will move, may 

rolling equipment enter or depart a “protected” track. When using a derail locked in the 

derailing position with the proper blue signal displayed at the derail, the protected track is the 

area between the locked derails. Therefore, other rolling equipment may enter and depart from 

that track, but cannot enter or depart the protected area of the track. Once blue signal protection 

is established, there can be no movement of rolling equipment within the protected area. In a 

situation involving a worker working a train under blue signal protection, road power could be 

added to the train by removing the blue signal on the head end only, thereby eliminating the need 

to walk to the rear. Similarly, this same worker can allow a train to depart after he removes the 

blue signal from the head end of the train. In both instances, work must stop while the blue 

signal has been removed. After the train has departed from the track, the remaining blue signal 

protection must be immediately removed. 

When a crossover switch leads into the track on which protected equipment is standing, the 

switches at both ends of the crossover must be lined against entry into the protected track. The 

switch at the end of that crossover which connects directly to the protected track must be locked, 

and blue signal must be displayed at that locked switch. However, if protected equipment is 

standing on the switch of such a crossover so as to block other equipment moves from entering 

the protected track through that crossover, the switch need not be locked or blue signal 

displayed. 

When workmen are engaged in work on a train with the rear portion standing on a track other 

than a main track, and the head end portion is on a main track, then the rear portion must be 

protected in accordance with § 218.27, “Workmen on track other than a main track,” while the 

head end would be protected by a blue signal ahead of the locomotive and one attached to the 

controlling locomotive in accordance with § 218.25, “Workmen on main track.” 

If one or more locomotives are among the protected equipment, then a blue signal must be 

displayed on the controlling locomotive at a location where it is readily visible to someone 

seated at the controls of that locomotive. The inspector should evaluate how visible and obvious 

the blue signal is to someone seated at the controls of the locomotive. The signal should be 

placed so that the operator does not have to look for it. A clamp hanging from the window sill 

with the blue signal positioned low on the car body of the locomotive would not comply. In 

other words, the signal must be immediately visible to the operator without any effort on his part. 

The absence of a blue signal at any one of the required locations means that the equipment is 

unprotected and workers may not work on, under, or between that equipment. 

If there is a single locomotive on one end of a yard track and a locomotive consist (with or 

without cars) is located on the other end of the same yard track and workers are replacing a brake 

shoe on the single locomotive, but no work is being performed on the other consist, the 

controlling locomotive of the consist and the single locomotive would both have to be blue 

flagged. 

Regulation
Federal Railroad Administration 

5 - 18

§218.29 Alternate methods of protection. 

Instead of providing blue signal protection for workers in accordance with§218.27, the following 

methods for blue signal protection may be used: 

(a) When workers are on, under, or between rolling equipment in a locomotive servicing track 

area: 

(1) A blue signal must be displayed at or near each switch providing entrance to or 

departure from the area; 

(2) Each switch providing entrance to or departure from the area must be lined against 

movement to the area and locked with an effective locking device; and 

(3) A blue signal must be attached to each controlling locomotive at a location where it is 

readily visible to the engineman or operator at the controls of that locomotive; 

(4) If the speed within this area is restricted to not more than 5 miles per hour a derail, 

capable of restricting access to that portion of a track within the area on which the rolling 

equipment is located, will fulfill the requirements of a manually operated switch in 

compliance with paragraph (a)(2) of this section when positioned at least 50 feet from the 

end of the equipment to be protected by the blue signal, when locked in a derailing 

position with an effective locking device, and when a blue signal is displayed at the 

derail; 

(5) A locomotive may be moved onto a locomotive servicing area track after the blue 

signal has been removed from the entrance switch to the area. However, the locomotive 

must be stopped short of coupling to another locomotive; 

(6) A locomotive may be moved off of a locomotive servicing area track after the blue 

signal has been removed from the controlling locomotive to be moved and from the area 

departure switch; 

(7) If operated by an authorized employee under the direction of the person in charge of 

the workers2

, a locomotive protected by blue signals may be repositioned within this area 

after the blue signal has been removed from the locomotive to be repositioned and the 

workers on the affected track have been notified of the movement; and 

(8) Blue signal protection removed for the movement of locomotives as provided in 

paragraphs (a) (5) and (6) of this section must be restored immediately after the 

locomotive has cleared the switch. 

(b) When workers are on, under, or between rolling equipment in a car shop repair track 

area: 

 

2 See FRA’s letter of clarification to dated May 18, 2009, at the end of this chapter.
 Motive Power and Equipment Compliance Manual 

5 - 19

1. A blue signal must be displayed at or near each switch providing entrance 

to or departure from the area; and 

2. Each switch providing entrance to or departure from the area must be lined 

against movement to the area and locked with an effective locking device; 

3. If the speed within this area is restricted to not more than 5 miles per hour, 

a derail capable of restricting access to that portion of a track within the 

area on which the rolling equipment is located will fulfill the requirements 

of a manually operated switch in compliance with paragraph (a)(2) of this 

section when positioned at least 50 feet from the end of the equipment to 

be protected by the blue signal, when locked in a derailing position with 

an effective locking device and when a blue signal is displayed at the 

derail; 

4. If operated by an authorized employee under the direction of the person in 

charge of the workmen, a car mover may be used to reposition rolling 

equipment within this area after workers on the affected track have been 

notified of the movement. 

(c) Except as provided in paragraphs (a) and (b) of this section, when workers are on, 

under, or between rolling equipment on any track, other than a main track: 

1. A derail capable of restricting access to that portion of the track on which 

such equipment is located, will fulfill the requirements of a manually 

operated switch when positioned no less than 150 feet from the end of 

such equipment; and 

2. Each derail must be locked in a derailing position with an effective 

locking device and a blue signal must be displayed at each derail. 

(d) When emergency repair work is to be done on, under, or between a locomotive or one 

or more cars coupled to a locomotive, and blue signals are not available, the engineman 

or operator at the controls of that locomotive must be notified and effective measures 

must be taken to protect the workers making the repairs. 

Guidance

This section provides a railroad with an alternate method of establishing blue signal protection 

for equipment occupying tracks in locomotive servicing areas and car shop repair track areas. At 

these locations, a railroad may establish blue signal protection in accordance with either § 

218.27, “Workers on track other than main track,” or in accordance with this section. The 

inspector must know whether § 218.27 or § 218.29 is being used before taking any kind of 

enforcement action. 

 
Federal Railroad Administration 

5 - 20

Basically, § 218.27 requires blue signal protection be established for each individual track, while 

§ 218.29 permits blue signal protection to be established for the area as a whole. It provides 

greater flexibility for movement of equipment within, as well as to and from, the area. This 

section also authorizes use of locked derails to fulfill the requirements of a manually operated 

switch on any track, other than a main track, when placed at a minimum distance of 150 feet 

from the end of the protected equipment. If speed is restricted to less than 5 mph, then this 

distance may be reduced to no less than 50 feet when used in locomotive servicing and car shop 

repair track areas, per 218.29(a) and (b). The 5 mph restriction may be conveyed by a physical 

sign or by a written bulletin or timetable instruction. If a derail is used, it must be locked in a 

derailing position with an effective locking device and a blue signal must be displayed at the 

derail. 

Blue signals must be attached to the controlling locomotive whenever workers are on, under, or 

between that locomotive or any rolling equipment attached to that locomotive. 

A locomotive not blue flagged within the area can be moved without removing blue signals 

displayed at the entrance switches provided: 

1. The locomotive does not impact or couple to a locomotive on which a blue signal is 

displayed. 

2. The locomotive is operated by an authorized employee under the direction of the person 

in charge of the workers. 

3. The workers on the affected track(s) where the movement will take place have been 

notified of the movement. 

When locomotives are moved into and out of the locomotive servicing area, the workers do not

have to stop work on locomotives that have a blue signal properly displayed. The blue signal 

protection must be immediately restored after any movement into or out of the servicing area. 

When inspecting for the adequacy of the blue signal protection in a locomotive servicing or car 

repair track area, first determine if workers are on, under, or between rolling equipment. Then 

determine if protection provided at each switch providing a means of entrance into the area is 

proper. Are the blue signals properly displayed? Physically test any locks, manual switches, and 

derails to ensure that they are secure. Next, observe the operations inside the area for 

compliance. 

 

Keep in mind when using the alternate method in locomotive servicing areas, every locomotive 

that has a worker working on, under, or between requires a blue signal attached to each 

controlling locomotive where it is readily visible to the operator at the controls of that 

locomotive. This means that if the locomotive is by itself (not coupled to another locomotive) it 

must have a blue signal displayed at its controls. If the locomotive being worked on was coupled 

to three other locomotives, then one of the following applies: 

1. If the four locomotives were pneumatically, electrically, and mechanically coupled 

together so that all four respond to the controls of only one locomotive (the lead unit), 

then only the controlling (lead) unit requires a blue signal displayed at the controls. 
 Motive Power and Equipment Compliance Manual 

5 - 21

2. If the four locomotives are coupled together but control cables and/or MU hoses are not 

connected so that all of the locomotives respond to one controlling locomotive, then all 

four locomotives would require a blue signal displayed at their controls. 

3. If the four locomotives are coupled together with the intent to make them a four-unit 

consist controlled from one locomotive, FRA has determined that the brake hoses and 

jumper cables could be connected after the automatic brake valve is cut out and the MU 

valves are placed in the trail position on three of the locomotives, and the controlling 

locomotive (automatic brake valve cut in) has a blue signal displayed at the controls. 

 Note: Unless the automatic brake valve is cut out and the MU valve is placed in the trail 

position, a blue signal has to be attached to all locomotives that are capable of being used 

as a controlling unit before the locomotive controls cables and MU cables are connected. 

Additionally, a worker cutting the automatic brake valve in or out and setting the MU valve is 

not considered a worker on the equipment. 

Remember, this provision has been made in the regulation for using alternate methods to 

reposition rolling equipment within the area. However, this may only be done when all 

conditions of the regulation are met. 

Regulation

§218.30 Remotely controlled switches. 

(a) After the operator of the remotely controlled switches has received the notification required 

by §218.27(c), he must line each remotely controlled switch against movement to that track and 

apply an effective locking device to the lever, button, or other device controlling the switch 

before he may inform the employee in charge of the workers that protection has been provided. 

(b) The operator may not remove the locking device unless he has been informed by the person 

in charge of the workers3

 that it is safe to do so. 

(c) The operator must maintain for 15 days a written record of each notification which contains 

the following information: 

(1) The name and craft of the employee in charge who provided the notification; 

(2) The number or other designation of the track involved; 

(3) The date and time the operator notified the employee in charge that protection had 

been provided in accordance with paragraph (a) of this section; and 

(4) The date and time the operator was informed that the work had been completed, and 

the name and craft of the employee in charge who provided this information. 

 

3 See FRA’s letter of clarification, dated May 18, 2009, at the end of this chapter.
Federal Railroad Administration 

5 - 22

 

Guidance

The operator referred to in this section is the employee who has been delegated the responsibility 

for the proper and safe operation of the control board. 

When the term effective locking device is used in reference to a remotely controlled switch, it 

need not be a padlock, but may be a plug or key that, when properly inserted into the control 

panel of the installation, serves to immobilize the switch control lever being used to establish 

protection. The device must be applied in such a manner that the control lever cannot be thrown 

for the route into the protected track without first removing the locking device. Whatever type 

locking device is utilized to immobilize the switch lever or button, it must effectively prevent it 

from being moved. A written tag alone, attached to the lever or button, that does not prevent the 

lever or button from being manipulated, would not comply. Any remotely controlled switch that 

can be overridden in the field by use of a manual lever without obtaining prior authority and 

taking that switch out of power would have to be treated as a manual switch and be locked in the 

field. 

Occasionally, a track on which blue signal protection is to be applied will have one or more 

switches that provide access to that track remotely controlled. If this is the case, certain 

measures must be taken by the carrier to insure adequate protection. When you find a location 

like this, check where these switches are being controlled. 

An inspection should be made of the written records the railroad is required to maintain. The 

written records should be inspected for their completeness as to: (1) the date and time the 

operator received notification of the work to be performed (Note: Item (1) is not a regulatory 

requirement. It is a suggestion as a good practice); (2) the name and craft of the employee in 

charge who provided the notification; (3) the number or other designation of the track involved; 

(4) the date and time the operator notified the employee in charge that protection has been 

provided in accordance with paragraph (a) of this section; and (5) the date and time the operator 

was informed that the work had been completed, and the name and craft of the employee in 

charge who provided this information. Such written records should be made at once and never 

from memory or memoranda. 

Check if effective locking devices are being applied to remotely controlled switches. 

Traditionally, levers, buttons, and similar devices have been used to control these switches. 

Mechanical locking devices, e.g., pins, clamps, sleeves, buttons or toggles would then be applied 

to these devices to prevent accidental removal of the protection. 

Increasingly, computer programs are now being used in place of levers, buttons, etc., to operate 

remotely controlled switches. The safeguard against accidental movement of a protected switch 

may not be so obvious with these systems. Applying a padlock, plug, or key would be 

impractical. The generally used method is for the computer program to require one or more 

extra entries with the computer’s keyboard before releasing the switch for movement. If only 

one additional step is required, evaluate whether it forces the operator to realize he or she is 

attempting to move a switch that has had blue signal protection applied to it. If you have a 

question concerning sufficient protection being provided, ask the operator to describe what steps 
 Motive Power and Equipment Compliance Manual 

5 - 23

he she must take. Can the operator provide and remove switch protection for each individual 

group of workers, or only for all employees at once? 

Regardless of the method used to operate remotely controlled switches, remember that the intent 

of the locking device provision is to force the operator to make some special effort to move a 

protected switch. This causes the operator to recall that there are workers on rolling equipment 

on the track. Use good judgment in determining if this has been accomplished. 

Inspections of remotely controlled switches will require a different reporting procedure. In most 

cases, blue signal inspection reporting may be entered on FRA Form F6180.96 together with any 

equipment-related inspection results. This is true for any blue signal inspections, except when 

remotely controlled switches are involved. The reason for this is that in most cases, control of 

blue signal protection is under the direct supervision of the mechanical department. Therefore, 

blue signal and equipment can be combined on the same report and presented to the responsible 

mechanical department official for handling. However, in the case of remotely controlled 

switches, a separate report on FRA Form F6180.96 with its own number will be required. 

It is best to leave a copy of your report with the railroad official directly responsible for the type 

of condition found. Remotely controlled switches are usually under the control of the 

transportation department, and defects must be handled with them for correction. Equipment 

conditions should be handled separately with a mechanical official, which is why there is a need 

for separate reports. The inspector should also leave a copy of this separate report with the 

mechanical department supervisor, because a failure in protection of a remotely controlled 

switch will most likely impact mechanical personnel. 
Federal Railroad Administration 

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 Motive Power and Equipment Compliance Manual 

5 - 25

 
6 - 1 

Chapter 6 

Rear End Marking Device–Passenger, Commuter, 

and Freight Trains, Part 221 

Introduction

This regulation was first published in January 1977 to reduce the risk of rear-end train collisions. 

This regulation requires that at least one highly visible marker be displayed at the trailing end of 

a passenger, commuter, and freight train during specified times and under certain weather 

conditions. The requirements of the regulation are generally self-explanatory. 

The regulation applies to railroads that operate more than one train at any given time on standard 

gage main track that is a part of the general railroad system of transportation. A railroad that 

operates only trains consisting of historical or antiquated equipment for excursion, educational, 

or recreational purposes, and urban rapid transit operations (not connected to the general railroad 

systems of transportation), are also excluded. 

In 1986, the regulation was amended in response to railroad operational changes (e.g., 

elimination of cabooses) and the development of newer technologies. The amended regulation 

allows: 

 Railroads to use personnel, other than train crew members, to perform rear marking 

device inspections (See Title 49 Code of Federal Regulations (CFR) Section 221.15(c)). 

 Railroads the use of radio telemetry in lieu of conducting a visual observation (See 

49 CFR § 221.15(d)). 

 Alternative procedures for establishing worker protection while performing a rear 

marker inspection on main track (See 49 CFR § 221.16(b)). 

Part 221 – Subpart A, General

§ 221.3 Application. 

(a) Except as provided in paragraph (b) of this section, this part applies to passenger, commuter, 

and freight trains when operated on a standard gage main track which is part of the general 

railroad system of transportation. 

(b) This part does not apply to: 

(1) A railroad that operates only trains consisting of historical or antiquated equipment 

for excursion, educational, or recreational purposes; 

(2) A train that operates only on track inside an installation which is not part of the 

general railroad system of transportation; 
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(3) Rapid transit operations in an urban area that are not connected with the general 

railroad system of transportation; 

(4) A railroad that operates only one train at any given time. 

Guidance 

Paragraph (b)(1) excludes railroads that only operate trains consisting of historical or antiquated 

equipment. A railroad that conducts regular freight and/or passenger train service, but 

occasionally operates a train consisting of historic or antiquated equipment, would be required to 

comply with the rule. 

Paragraph (b)(4) applies to railroads that operate only one train at any given time. It does not 

exclude trains operated on a railroad’s branch line. 

§ 221.5 Definitions. 

As used in this part: 

(a) Train means a locomotive unit or locomotive units coupled, with or without cars, involved in 

a railroad operation conducted on a main track. It does not include yard movements. 

Guidance 

The term “yard movements,” as used in paragraph (a), references movements of on-track rail 

equipment within the designated limits of a yard. By including such language, the rule excludes 

most switching operations when performed solely within the confines of a railroad yard. If, for 

example, if a yard job with the locomotive in the lead pulled out onto a main track for headroom 

only in order to make a shove, the rear of the train wouldn’t be on the main track and the train 

wouldn’t require a marker. If the trailing end of the rear car makes it onto the main line outside 

the designated yard limits, then the equipment becomes a “train” for the purposes of Part 221 and 

the requirements of the regulation would apply. 

§ 221.13 Marking device display. 

(a) During the periods prescribed in paragraph (b) of this section, each train to which this part 

applies that occupies or operates on main track shall (1) be equipped with, (2) display on the 

trailing end of the rear car of that train, and (3) continuously illuminate or flash a marking device 

prescribed in this subpart. 

(b) Unless equipped with a functional photoelectric cell activation mechanism complying with 

paragraph (c) of this section, the marking devices prescribed by this subpart shall be illuminated 

continuously or flash during the period between one hour before sunset and one hour after 

sunrise, and during all other hours when weather conditions so restrict visibility that the end 
Motive Power and Equipment Compliance Manual 

6 - 3 

silhouette of a standard box car cannot be seen from 1⁄2 mile on tangent track by a person having 

20/20 corrected vision. 

(c) Marking devices prescribed by this part and equipped with a functioning photoelectric cell 

activation mechanism shall illuminate or flash the device continuously when there is less than 

1.0 candela per square meter of ambient light. 

(d) The centroid of the marking device must be located at a minimum of 48 inches above the top 

of the rail. 

Guidance

An operating rear end marking device is required to be displayed at the rear end of trains 

operating on, or occupying, a main line track during periods of restricted visibility. If part of a 

train is within the yard limits, but the rear car of the train still occupies the main track, a marking 

device would be required to be displayed until such time as the rear car of the train no longer 

occupied the main track. Per § 221.14(c), when a locomotive is operated singly, or at the rear of 

a train (including at the rear of a lite locomotive consist), the rear headlight of the locomotive 

illuminated on low beam will satisfy the rear end marking device requirement. 

§ 221.15 Marking device inspection. 

(a) Each marking device displayed in compliance with this part shall be examined at each crew 

change point to assure that the device is in proper operating condition. 

(b) This examination shall be accomplished either by visually observing that the device is 

functioning as required or that the device will function when required by either: 

 

(1) repositioning the activation switch or 

(2) covering the photoelectric cell. 

(c) This examination shall be conducted either by the train crew or some other qualified person, 

provided that, if a non-train crewmember performs the examination, that person shall 

communicate his or her findings to the locomotive engineer of the new train crew. 

(d) When equipped with a radio telemetry capability, a marker displayed in accordance with this 

part may be examined by observing the readout information displayed in the cab of the 

controlling locomotive demonstrating that the light is functioning as required in lieu of 

conducting a visual observation. 

Guidance

Most (but not all) rear end marking devices are equipped with a photoelectric cell that will 

illuminate the marking device during reduced ambient lighting conditions. The device should 

operate as intended and its operation should be examined at each crew change point. The 
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examination can be accomplished either visually or (when equipped) by using radio telemetry. If 

a visual examination is performed by personnel other than a train crew member assigned to the 

train, the results of the examination must be communicated to the locomotive engineer. 

§ 221.16 Inspection procedure. 

(a) Prior to operating the activation switch or covering the photoelectric cell when conducting 

this test, a non-train crew person shall determine that he is being protected against the 

unexpected movement of the train either under the procedures established in part 218 of this 

chapter or under the provisions of paragraph (b) of this section. 

(b) In order to establish the alternative means of protection under this section, 

(1) the train to be inspected shall be standing on a main track; 

(2) the inspection task shall be limited to ascertaining that the marker is in proper 

operating condition; and 

(3) prior to performing the inspection procedure, the Inspector shall personally contact 

the locomotive engineer or hostler and be advised by that person that they are occupying 

the cab of the controlling locomotive and that the train is and will remain secure against 

movement until the inspection has been completed. 

Guidance

This section of the regulation provides the procedures for establishing protection for non-train 

crew members while performing rear end marking device examinations as required by § 

221.15(a) discussed above. If the train is standing on a main track and the task is limited to 

ascertaining the proper operation of the device, prior to performing the inspection the non-train 

crew member must personally contact the locomotive engineer positioned in the cab of the 

controlling locomotive and receive assurances from the locomotive engineer that the train will 

remain secure from movement until the inspection is completed. However, this section is not 

applicable if the proper operation of the device can be ascertained without positioning the nontrain crew member in danger of injury due to unexpected movement of the equipment, and 

without the train crew member having to operate the activation switch or cover the photoelectric 

cell when conducting the test. Finally, if it becomes necessary for the railroad employee to 

perform tasks other than ascertaining the proper operation of the device, or if the train is located 

on other than main track, then the provisions of Subpart B of Part 218 (Blue signal protection of 

workers) would instead apply. 

§ 221.17 Movement of defective equipment. 

(a) Whenever the marking device prescribed in this part becomes inoperative enroute, the train 

may be moved to the next forward location where the marking device can be repaired or 

replaced. 
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6 - 5 

(b) Defective rolling equipment which, because of the nature of the defect, can be placed only at 

the rear of a train for movement to the next forward location at which repairs can be made need 

not be equipped with marking devices prescribed in this part. 

(c) When a portion of a train has derailed, and a portable marking device is not available, the 

remainder of the train may be moved to the nearest terminal without being equipped with the 

marking device prescribed in this part. 

Guidance

The expectation of the rule is that railroads will maintain a sufficient number of approved rear 

end marking devices on their system to comply with the regulation. FRA safety inspectors 

should become sufficiently familiar with each railroad operation within their assigned inspection 

territory, to determine where marking devices are maintained and available. The regulation 

allows a railroad to continue the movement of a train that experiences a marking device failure 

while en route. The inoperative device must be repaired or replaced at the next forward location 

where such replacement or repairs can be made. 

Although most end-of-train devices (EOT) incorporate a rear end marking device that is built 

into the EOT, the separate regulatory requirements for the two devices can be misinterpreted. 

Each device accomplishes a separate function; the rear end marker increases visibility of trains 

during low ambient lighting conditions, while the EOT transmits information to the head-end of 

the train, via radio telemetry. Another distinction is that all trains are required to have an 

operating rear end marking device (during specified low ambient lighting conditions), but not all 

trains are required to be equipped with an EOT. It is especially important to become familiar 

with and understand the differences between the “en route failure” requirements specified in both 

regulations (See Part 232, Subpart E). Deficiencies and/or recommendations for civil penalty 

should reference the appropriate regulation (Part 221 for rear end marking device, or Part 232 for 

EOT). 

Approved Rear End Marking Devices

Part I–Approved Devices Tested For or By Manufacturers 

Star Headlight & Lantern Co.; 168 West Main Street; Honeoye Falls, NY 14472. 

FRA identification Nos. FRA-PLE-STAR-845-F (flasher) and FRA-PLE-STAR-845-C (steady 

burn). 

Julian A. McDermott Corp.; 1639 Stephen Street; Ridgewood, Long Island, NY 11227. 

FRA identification Nos. FRA-MEC-MCD-100-C (steady burn), FRA-MEC-MCD-100-F 

(flasher), FRA-MEC-MCD-300-C (steady burn), and FRA-MEC-MCD-300-F (flasher). 

American Electronics, Inc.; 1 40 Essex Street; Hackensack, NJ 07601. 

NOTE: Yankee Metal Products Corp. previously produced these devices. 

FRA identification Nos. FRA-DRGW-YANK-300 (portable strobe), FRA-WP-YANK-301R 

(flashing), FRA-WP-YANK-305R (flashing), and FRA-WP-YANK-306R (steady burn). 
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 PART II–Approved Devices Tested For or By Rail Carriers 

1. Carrier: Atchison, Topeka & Santa Fe Railway Co.; Technical Research & Development 

Department; 1001 Northeast Atchison Street; Topeka, KS 66616. 

Manufacturer: Trans-Lite, Inc.; P.O. Box 70; Milford, CT 06460. 

FRA identification Nos. FRA-ATSF-TL-875-150, FRA-ATSF-TL-875-60, FRA-ATSF-TL-875-

4412, and FRA-ATSF-TL-200. 

2. Carrier: Amtrak (National Railroad Passenger Corporation), 400 North Capitol Street NW; 

Washington, DC 20001. 

Manufacturer: (a) Trans-Lite, Inc.; P.O. Box 70; Milford, CT 06460. 

FRA identification Nos. FRA-ATK-TL-3895-1, FRA-ATK-TL-4491-2, FRA-ATK-TL-4491-3, 

and FRA-ATK-TL-FM-4491-1. 

Manufacturer: (b) Luminator Division of Gulfton Industries, Inc.; 1200 East Dallas North 

Parkway; Plano, TX 75074. 

FRA identification No. FRA-ATK-LUM-0101890-001. 

Manufacturer: (c) Whelen Engineering Co., Inc.; Deep River, CT 06417. 

FRA identification No. FRA-ATK-WHE-WERT-12. 

Guidance

Since the regulation was published, FRA has approved additional devices. The following 

supplement is a listing of the current approved marking devices: 

Manufacturer Model Number

ALLCOM Products LLC 

695 Sundown Road 

South Eglin, IL 60177 

#RRP-265 Series LED 

American Electronics, Inc.1

40 Essex Street 

Hackensack, NJ 07601 

#300, #301, #305, #306 

R. E. Deitz Company 

225 Wilkinson Street 

Syracuse, NY 13201 

#70-21/NAPA 510 

DPS Electronics 

2435 Outlaw Lane 

Belgrade, MT 59714 

#DPS HVM II 

 

1 Yankee Metal Products Corp. previously produced these devices. 
Motive Power and Equipment Compliance Manual 

6 - 7 

Dialight Corporation 

1501 Route 34 South 

Farmington, NJ 07727 

#PAR46 LED Rail Car Marker Light 

Donovan Associates 

P.O. Box 212 

Exton, PA 19341 

#21079 

Dynamic Sciences Limited 

359 St. Croix Blvd. 

St. Laurant, Quebec H4N 2l3 

Canada 

HVM-401 (also integrated in Digitar Unit) 

Federal Sign and Signal Co. 

140 East Tower-Burridge 

Chicago, IL 

#372 

General Electric 

P.O. Box 1262 

Reading, PA 10603 

—1 (60 PAR/2/R) 

Grimes Manufacturing Co. 

Midland Ross Corp. 

515 North Russell Street 

Urbana, OH 43078 

85-0583-3, 85-0602-1 

Illinois Central Gulf 2

Two Illinois Center 

233 North Michigan Avenue 

Chicago, IL 60601 

High Liner-P 36 

Julian A. McDermott Corp. 

1639 Stephan Street 

Long Island, NY 11227 

Series 100 (Flasher) ; Series 100 (Steady) 

Series 300 (Flasher) ; Series 300 (Steady) 

Liteco, Inc. 

205 Main Street 

Chester, NJ 07930 

36F and REI 36F-2A 

Luminator Division 

Gulfton Industries Inc. 

1200 East Dallas North Parkway, Plano, TX 

75074 

#103086, #0101890-001 

Matrix Railway Corporation 

69 Nancy Street 

West Babylon, NY 11704 

P21926-2 (LED) 

 

2

 1437 Marker Light Manufactured by Adams and Westlake Co., Elkhart, Indiana and 

redesigned by Signal-Stat Co., 1200 Commerce Avenue, Union New Jersey 07803 
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Power Parts Co. 

1860 N. Wilmot Avenue 

Chicago, IL 60647 

#12155 

Pulse Electronics, Inc. 

5706 Frederick Ave. 

Rockville, MD 20852 

FRA-BN-Pulse 4401 RTP (Portable) 

FRA-BN-Pulse Train line II 

Pyle National 

1334 North Kostner 

Chicago, IL 60651 

20585DCJ (200PAR56) 

Quantum Engineering, Inc. 

352 Stowe Avenue 

Orange Park, FL 32073 

Q348x (LED) 

Railhead Corporation 

10721 S. Western Avenue 

Chicago, IL 60643 

#MK III USA 

Safety Products Co. 

6144 North Avenue 

Chicago, IL 

#6551-77RTVL 

Star Headlight and Lantern Co. 

168 West Main Street 

Honoye Falls, NY 14472 

845 (Flasher), #845 (Steady) 

845S 

860-F, #861-F Portables 
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Translite Incorporated 

P.O. Box 70 

Milford, CT 06460 

FM-875-2 (GE-4413R PAR 46) 

FM-875-2 (GE 60 PAR/2/R) 

FM-3895-1, (GE 60 PAR/2/R 

F-875 (150 PAR 46) 

F-875 (60 PAR 46) 

F-875 (4412 PAR 46) 

C-1785(200 PAR 56) 

FM-4 491-1 

FM-4491-2 

FM-4491-3 

RC-4193 

FM-886 

FM-886A 

FM-5050-1 

FM-5050-2 

FM-5050-3 

RC-2412 

FM-5060-1 

FM-2304 

FM-5051-75 V 

FM-5051-32V 

FM-5158 

FM-5403 

FM-6227 

M - 46-1 (LED) 

Union Switch & Signal Inc. 

P.O. Box 539 

Batesburg, SC 29006 

(Digitar) 6695 Rear Telemetry Unit 

Utah Transit Authority 

3600 South 700 West 

P.O. Box 30810 

Salt Lake City, UT 84130 

Motive Power Inc. application of the General 

Electric (GE) 60PAR/2/R TRAIN sealed 

beam lamp 

Luminator Rear End Marking Device P/N 

110103-001 

Wabtec Railway Electronics 

21200 Dorsey Mill Road 

Germantown, MD 20876 

22161P 22415P 22810P 22899P 

23131P 23743P 23792P 24071P 

24186P 24201P 24261P 24262P 

24973P 25244P 25455P 26062P 

26482P 26494P 26495P 26621P 

27340P 27385P 

Whalen Engineering Co., Inc. 

Deep River, CT 06417 

WERT-12 
7 - 1 

Chapter 7 

Safety Glazing Standards– 

Locomotives, Passenger Cars, and Cabooses, Part 223 

Guidance 

The Safety Glazing Standards contained in part 223 establish minimum safety requirements for 

glazing materials in the windows of locomotives, passenger cars, and cabooses in order to reduce 

the risk of death or serious injury for railroad crew members and railroad passengers from flying 

objects, including bullets. Although the actual regulation is relatively self-explanatory, there are 

some items of interest that inspectors need to know to help with compliance activities. 

There have been questions raised concerning the rule language in §223.9 Requirements for new 

or re-built equipment does not contain the requirement of Type I or Type II glazing for 

locomotives and passenger cars. Please be advised that such requirements can be found in the 

Appendix A to this Part, at item (10) and (11) for Type I (see Figure 1) and Type II (see Figures 

1 and 2 above), respectively.

Glazing Waivers

Inspectors should ask their regional specialist whether a railroad or equipment owner has a 

glazing waiver before pursuing any enforcement action. Numerous glazing waivers have been 

granted by FRA’s Railroad Safety Board in accordance with the requirements contained in 49 

CFR part 211. Glazing waivers exempt specific equipment, owned by specific railroads or 

equipment owners from the requirements of part 223. If additional information related to an 

existing waiver is need, a railroad or equipment owner should produce evidence related to the 

waiver, including FRA’s letter granting their waiver request. 

When an inspector is assigned to investigate a waiver request for glazing, the following 

information is needed by the Railroad Safety Board in order to process the waiver: 

Figure 2: Coach car with FRA-approved 

Type II (side-facing) glazing. 

Figure 1: Locomotive with FRA-approved 

Types I (front-facing) & II (side-facing). 
Federal Railroad Administration 

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 (Note: Paragraph concerning obtaining written estimate for glazing waivers has since 

been deleted. It is based on Railroad Safety Board decision reached on September 23, 

2011). 

 A description of the operating environment, including the areas of operation (city or 

rural), any grade crossings, the maximum authorized speed, and the specific route(s). 

 Information regarding the history for window breakage and/or vandalism. 

 The date the equipment was built; and, 

 Any other pertinent information. The information must be fact, not opinion. 

Locomotive Glazing 

Locomotives that have supplementary bay windows added to the side of the locomotive are not 

required to meet the safety glazing standards. These windows are normally used only during 

periods of adverse weather and are intended to improve crew visibility without exposing the 

crew to the adverse weather. It was never FRA’s intent to include these supplementary 

windows, since they are used as an addition to existing glazing that must meet the impact 

requirements of this regulation. 

Carbody type locomotives, such as model numbers F-9, F-40PH, E-9, SD40C, etc., have 

windows and portholes in the end doors and the side carbody that enclose the motor. Since these 

are areas that are not in close proximity to the railroad worker during normal locomotive 

operations, such windows do not require the use of impact resistant glazing. Only windows 

located in the cab areas are required to have the safety glazing materials. 

Passenger Equipment Glazing 

The Passenger Equipment Safety Standards have included additional requirements for glazing 

applications in 49 CFR § 238.221 for Tier I equipment. This section basically addresses the 

performance of the frame that attaches to the car body. It is intended to ensure the glazing stays 

in place when subjected to air pressure differences caused when two trains pass at the minimum 

separation for two adjacent tracks. It also secures the window glazing in place so it can resist 

spalling when struck by a projectile, and also resist being knocked out of the window frame. 

The Passenger Equipment Safety Standards have included additional requirements for glazing 

applications in 49 CFR § 238.421 for Tier II equipment. These standards are far more stringent 

standards than prescribed in part 223. This section applies to all passenger equipment that 

operates at speeds in excess of 125 mph, not to exceed 150 mph. 

Application of the Glazing Safety Standards 

In 49 CFR § 223.3(b)(3), FRA’s interpretation of the terms “historical,” “antiquated,” and 

“excursion” are as follows: 
Motive Power and Equipment Compliance Manual 

7 - 3

Historical equipment refers to locomotives, passenger coaches, or cabooses that have historical 

significance. For example, the Ferdinand Magellan, U.S.A.-1 passenger car used by President 

Roosevelt is considered historical equipment. 

Antiquated equipment FRA considers passenger cars built prior to the end of World War II (1945 

or earlier) to be antiquated. 

Excursion means an operation that transports passengers to one or more points of interest and 

returns them to the original point of departure. 
8 - 1 

Chapter 8 

Railroad Locomotive Safety Standards, Part 229 

Introduction

In 1980, the Federal Railroad Administration (FRA) revised the sections of Title 49 Code of 

Federal Regulations (CFR) part 230 related to non-steam locomotive inspection and maintenance 

standards, and moved them into part 229. 

The following guidelines are to be used by Federal and State inspectors when conducting 

inspections of locomotives for compliance with Federal safety laws. To ensure uniform 

enforcement of the Federal safety laws, it is important that inspectors adhere to all agency 

enforcement policies when conducting inspections. 

The procedures and guidance provided in both this manual and the General Manual should be 

observed when determining appropriate corrective actions in response to noncompliance with 

part 229 or other safety defects. When a Motive Power and Equipment (MP&E) inspector finds 

a safety defect, the inspector should decide if the defect(s): 

(a) Is a noncompliant condition based on the requirements of part 229. 

(b) Should be documented on the FRA Form F6180.96, Inspection Report. 

(c) Warrants the issuance of a violation, and assessment of a civil penalty. 

(d) Warrants the issuance of a Special Notice for Repair (Special Notice), as provided 

for in 49 CFR part 216. 

(e) Should be reported to the railroad as an unsafe condition(s) that is not specifically 

encompassed in Federal regulation. 

MP&E inspectors will conduct most of their locomotive inspections at either a facility where 

periodic, annual, and biennial tests are performed; or at a location where locomotives are 

serviced and prepared for train service. However, with the increase of locomotive calendar-day 

inspections being performed by railroad transportation department employees away from 

mechanical facilities, it is important that the MP&E inspectors schedule time to monitor these 

practices for full compliance with Federal safety laws. 

A locomotive should comply with all requirements contained in part 229 and be free from any

safety defects. Keep in mind, a locomotive may not be absolutely clean and free from all 

accumulations of oil, but still be in compliance. Part 229 addresses conditions that create an 

unsafe working environment, an unsafe condition, or an unsafe locomotive. It does not address 

housekeeping practices of a railroad. Anytime a locomotive has been recently released from a 

periodic test and is found with a noncompliant condition, a violation should strongly be 

considered. 
Federal Railroad Administration 

8 - 2 

When an inspector discovers and substantiates a noncompliant condition that he/she believes 

makes a locomotive unsafe and not fit for service, a Special Notice, as provided for by 49 CFR 

part216, may be issued to the railroad. The Special Notice should describe the condition or 

conditions for which it was issued. Except in rare circumstances, a violation must be submitted 

with any Special Notice for Repair. 

Any railroad employee who authorizes the willful movement or operation of a noncomplying or 

unsafe locomotive, and who has knowledge of the circumstances, can be held personally 

responsible for the action. The inspector should judge all pertinent facts and determine if it can 

be documented that the railroad employee can be cited for willful noncompliance with Federal 

safety laws. Prior to advising a railroad employee that he/she will be cited for a willful violation, 

the inspector must coordinate such action in accordance with established procedures. (See 

General Manual.) 

Locomotive Safety Standards Inspection Procedures

Upon arrival at an inspection point where mechanical department personnel are assigned to 

perform locomotive inspection, testing, and repair, the inspector should notify the local railroad 

supervisor of his/her presence and intentions. The railroad will determine whether an employee 

will accompany the inspector. However, in some instances, it is not always advantageous to 

notify the railroad of FRA’s presence, especially if an inspection is related to a complaint or 

investigation. 

It is not necessary for FRA inspectors to obtain “blue signal” protection when conducting any 

type of inspection activity. However, inspectors should be alert and not place themselves in a 

position where the unexpected movement of equipment subjects them to the danger of personal 

injury. Railroad representative(s) accompanying the inspector during the inspection must obtain 

blue signal protection if they engage in activities that require them to work on, under, or between 

the equipment. 

Testing or operating any railroad equipment shall be performed by railroad personnel, not FRA 

inspectors. Where practical, the inspector should observe tests of the air brakes, speed 

indicators, high-voltage ground protection, and wheel slip/slide protection. The inspector should 

point out any observed conditions, whether covered by the regulations or not, that would 

jeopardize employee safety and/or the safe operation of the equipment. 

After the inspection, advise the proper railroad representative of all noncomplying conditions. 

The inspector must use discretion in evaluating the condition of the equipment and whether to 

cite the defects on his/her inspection report. Although a railroad need not have knowledge of a 

noncomplying condition on a locomotive to be assessed a civil penalty under the Locomotive 

Safety Standards, each inspector is expected to use sound judgment along with the guidance 

outlined in the General Manual when deciding whether the issuance of a violation report is 

appropriate under the circumstances. The purpose of the civil penalty is to promote compliance, 

not punish a railroad for each and every noncomplying condition regardless of the circumstances. 

Accordingly, each inspector should limit the issuance of violation reports to situations where 

civil penalties will promote compliance. If a railroad makes a serious, good-faith effort to 
Motive Power and Equipment Compliance Manual 

8 - 3 

comply with the standards, the filing of a violation report for an isolated, difficult to detect, 

noncomplying condition would serve no valid enforcement purpose. 

The railroad should be notified of all cited conditions in a timely manner, so that appropriate 

corrective action can be taken. Inspectors do not have the option or authority to authorize a 

railroad to use a noncomplying locomotive once a defective condition is cited. The Inspection 

Report should be completed and appropriate copies given to the railroad representative. If the 

inspection report cannot be prepared immediately after the inspection, then one must be 

completed during the next work period and delivered or forwarded to a railroad representative. 

Subpart A – General

§ 229.1 Scope. 

This part prescribes minimum Federal safety standards for all locomotives except those propelled 

by steam power. 

§ 229.3 Applicability. 

(a) Except as provided in paragraph (b) through (e) of this section, this part applies to all 

standard gage railroads. 

(b) This part does not apply to: 

(1) A railroad that operates only on track inside an installation which is not part of 

the general railroad system of transportation; or 

(2) Rapid transit operations in an urban area that are not connected with the 

general railroad system of transportation. 

(c) Paragraphs (a) and (b) of § 229.125 do not apply to Tier II passenger equipment as 

defined in § 238.5 of this chapter (i.e., passenger equipment operating at speeds 

exceeding 125 mph but not exceeding 150 mph). 

(d) On or after November 8, 1999, paragraphs (a)(1) and (b)(1) of § 229.141 do not apply 

to “passenger equipment” as defined in § 238.5 of this chapter; unless such equipment is 

excluded from the requirements of §§ 238.203 through 238.219, and § 238.223 of this 

chapter by operation of § 238.201(a)(2) of this chapter. 

(e) Paragraphs (a)(2) through (a)(4), and (b)(2) through (b)(4) of § 229.141 do not apply 

to “passenger equipment” as defined in § 238.5 of this chapter that is placed in service for 

the first time on or after September 8, 2000, unless such equipment is excluded from the 

requirements of §§ 238.203 through 238.219, and § 238.223 of this chapter by operation 

of § 238.201(a)(2) of this chapter. 

Guidance
Federal Railroad Administration 

8 - 4 

Section (b)(1): The inspector should be aware that if a locomotive(s) of a private 

industry operates over a portion of a general railroad system’s yard or tracks, such 

locomotives must be in compliance with the Locomotive Safety Standards and other 

appropriate regulations. Legal action could be taken against the industrial railroad if their 

locomotives are not in compliance, but FRA usually holds the general railroad 

responsible and liable for the industrial locomotives which it permits to be used on its 

lines. If an industry leases a track in an adjacent railroad yard for its exclusive use, it 

may operate over that track as if it was part of the industrial facility and the locomotives 

do not come under the Locomotive Safety Standards. (See 49 CFR § 209 Appendix A.) 

Whenever there is a question as to whether a railroad’s operation and/or equipment fall 

under the requirements of Part 229, the regional office should be contacted for 

confirmation. 

§ 229.4 Information Collection. 

Guidance 

This part relates to information collection under part 229, which was reviewed by the Office of 

Budget and Management. No enforcement action is attached to this part. 

§ 229.5 Definitions. 

As used in this part— 

Break means a fracture resulting in complete separation into parts. 

Cab means that portion of the superstructure designed to be occupied by the crew operating the 

locomotive. 

Carrier means railroad, as that term is in this section. 

Commuter service means the type of railroad service described under the heading “Commuter 

Operations” in 49 CFR Part 209, Appendix A. 

Commuter work train is a non-revenue service train used in the administration and upkeep 

service of a commuter railroad. 

Control cab locomotive means a locomotive without propelling motors but with one or more 

control stands. 

Controlling remote distributed power locomotive means the locomotive in a distributed power 

consist that receives the coded signal from the lead locomotive consist of the train whether 

commanded automatically by the distributed power system or manually by the locomotive 

engineer. 
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8 - 5 

Crack means a fracture without complete separation into parts, except that castings with 

shrinkage cracks or hot tears that do not significantly diminish the strength of the member are not 

considered to be cracked. 

Cruise control means a device that controls locomotive power output to obtain a targeted speed. 

A device that functions only at or below 30 miles per hour is NOT considered a “cruise control” 

for purposes of this part. 

Data element means one or more data point or value reflecting on-board train operations at a 

particular time. Data may be actual or “passed through” values or may be derived from a 

combination of values from other sources. 

Dead locomotive means— 

(1) A locomotive, other than a control cab locomotive, that does not have any traction 

device supplying tractive power; or 

(2) A control cab locomotive that has a locked and unoccupied cab. 

Distributed power system means a system that provides control of a number of locomotives 

dispersed throughout a train from a controlling locomotive located in the lead position. The 

system provides control of the rearward locomotives by command signals originating at the lead 

locomotive and transmitted to the remote (rearward) locomotives. 

DMU locomotive means a diesel-powered multiple unit operated locomotive with one or more 

propelling motors designed to carry passenger traffic. 

Electronic air brake means a brake system controlled by a computer which provides the means 

for control of the locomotive brakes or train brakes or both. 

Event recorder means a device, designed to resist tampering, that monitors and records data, as 

detailed in § 229.135(b), over the most recent 48 hours of operation of the electrical system of 

the locomotive on which the device is installed. However, a device, designed to resist 

tampering, that monitors and records the specified data only when the locomotive is in motion 

meets this definition if the device was installed prior to November 5, 1993 and if it records the 

specified data for the last eight hours the locomotive was in motion. 

Event recorder memory module means that portion of the event recorder used to retain the 

recorded data as detailed in § 229.135(b). 

High voltage means an electrical potential of more than 150 volts. 

In-service event recorder means an event recorder that was successfully tested as prescribed in 

§ 229.27(d) and whose subsequent failure to operate as intended, if any, is not actually known by 

the railroad operating the locomotive on which it is installed. 

Lead locomotive means the first locomotive proceeding in the direction of movement.
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Lite locomotive means a locomotive or a consist of locomotives not attached to any piece of 

equipment or attached only to a caboose. 

Locomotive means a piece of on-track equipment other than hi-rail, specialized maintenance, or 

other similar equipment— 

 (1) With one or more propelling motors designed for moving other equipment; 

(2) With one or more propelling motors designed to carry freight or passenger traffic or 

both; or 

 (3) Without propelling motors but with one or more control stands. 

Mandatory directive means any movement authority or speed restriction that affects a railroad 

operation. 

Modesty lock means a latch that can be operated in the normal manner only from within the 

sanitary compartment that is designed to prevent entry of another person when the sanitary 

compartment is in use. A modesty lock may be designed to allow deliberate forced entry in the 

event of an emergency. 

MU locomotive means a multiple unit operated electric locomotive– 

 

(1) With one or more propelling motors designed to carry freight or passenger traffic or 

both; or 

 (2) Without propelling motors but with one or more control stands. 

Other short-haul passenger service means the type of railroad service described under the 

heading “Other short-haul passenger service” in 49 CFR Part 209, Appendix A. 

Potable water means water that meets the requirements of 40 CFR Part 141, the Environmental 

Protection Agency’s Primary Drinking Water Regulations, or water that has been approved for 

drinking and washing purposes by the pertinent state or local authority having jurisdiction. For 

purposes of this part, commercially available, bottled drinking water is deemed potable water. 

Powered axle is an axle equipped with a traction device. 

Railroad means all forms of non-highway ground transportation that run on rails or 

electromagnetic guideways, including (1) commuter or other short-haul rail passenger service in 

a metropolitan or suburban area, and (2) high speed ground transportation systems that connect 

metropolitan areas, without regard to whether they use new technologies not associated with 

traditional railroads. Such term does not include rapid transit operations within an urban area that 

are not connected to the general railroad system of transportation. 
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Remanufactured locomotive means a locomotive rebuilt or refurbished from a previously used or 

refurbished underframe (“deck”), containing fewer than 25 percent (25%) previously used 

components (weighted by dollar value of the components). 

Sanitary means lacking any condition in which any significant amount of filth, trash, or human 

waste is present in such a manner that a reasonable person would believe that the condition might 

constitute a health hazard; or of strong, persistent, chemical or human waste odors sufficient to 

deter use of the facility, or give rise to a reasonable concern with respect to exposure to 

hazardous fumes. Such conditions include, but are not limited to, a toilet bowl filled with human 

waste, soiled toilet paper, or other products used in the toilet compartment, that are present due 

to a defective toilet facility that will not flush or otherwise remove waste; visible human waste 

residue on the floor or toilet seat that is present due to a toilet that overflowed; an accumulation 

of soiled paper towels or soiled toilet paper on the floor, toilet facility, or sink; an accumulation 

of visible dirt or human waste on the floor, toilet facility, or sink; and strong, persistent chemical 

or human waste odors in the compartment. 

Sanitation compartment means an enclosed compartment on a railroad locomotive that contains a 

toilet facility for employee use. 

Self-monitoring event recorder means an event recorder that has the ability to monitor its own 

operation and to display an indication to the locomotive operator when any data required to be 

stored are not stored or when the stored data do not match the data received from sensors or data 

collection points.

Serious injury means an injury that results in the amputation of any appendage, the loss of sight 

in an eye, the fracture of a bone, or the confinement in a hospital for a period of more than 24 

consecutive hours. 

Switching service means the classification of railroad freight and passenger cars according to 

commodity or destination; assembling cars for train movements; changing the position of cars 

for purposes of loading, unloading, or weighing; placing locomotives and cars for repair or 

storage; or moving rail equipment in connection with work service that does not constitute a train 

movement. 

Throttle position means any and all of the discrete output positions indicating the speed/tractive 

effort characteristic requested by the operator of the locomotive on which the throttle is installed. 

Together, the discrete output positions shall cover the entire range of possible speed/tractive 

effort characteristics. If the throttle has continuously variable segments, the event recorder shall 

capture either: (1) the exact level of speed/tractive effort characteristic requested, on a scale of 

zero (0) to one hundred percent (100%) of the output variable or (2) a value converted from a 

percentage to a comparable 0 to 8 digital signal. 

Time means either “time-of-day” or “elapsed time” (from an arbitrarily determined event) as 

determined by the manufacturer. In either case, the recorder must be able to convert to an 

accurate time-of-day with the time zone stated unless it is Greenwich Mean Time (GMT) or 

Coordinated Universal Time (UTC). 
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Toilet facility means a system that automatically or on command of the user removes human 

waste to a place where it is treated, eliminated, or retained such that no solid or non-treated 

liquid waste is thereafter permitted to be released into the bowl, urinal, or room and that prevents 

harmful discharges of gases or persistent offensive odors. 

Transfer service means a freight train that travels between a point of origin and a point of final 

destination not exceeding 20 miles and that is not performing switching service. 

 

Unsanitary means having any condition in which any significant amount of filth, trash, or human 

waste is present in such a manner that a reasonable person would believe that the condition might 

constitute a health hazard; or strong, persistent, chemical or human waste odors sufficient to 

deter use of the facility, or give rise to a reasonable concern with respect to exposure to 

hazardous fumes. Such conditions include, but are not limited to, a toilet bowl filled with human 

waste, soiled toilet paper, or other products used in the toilet compartment, that are present due 

to a defective toilet facility that will not flush or otherwise remove waste; visible human waste 

residue on the floor or toilet seat that is present due to a toilet that overflowed; an accumulation 

of soiled paper towels or soiled toilet paper on the floor, toilet facility, or sink; an accumulation 

of visible dirt or human waste on the floor, toilet facility, or sink; and strong, persistent chemical 

or human waste odors in the compartment. 

Washing system means a system for use by railroad employees to maintain personal cleanliness 

that includes a secured sink or basin, water, antibacterial soap, and paper towels; or antibacterial 

waterless soap and paper towels; or antibacterial moist towelettes and paper towels; or any other 

combination of suitable antibacterial cleansing agents. 

Guidance 

Section (c): Carrier The designation “carrier” should not be used in referring to a railroad. The 

Rail Safety Improvement Act of 1988 (RSIA 88) did away with the phrase “common carrier,” 

and required that the word “railroad” be inserted in all FRA regulations that previously used the 

word carrier or common carrier. 

Section (d): Control Cab Locomotive This could be either a passenger coach with a control 

stand located at one end, where the operator can operate a passenger train with the locomotive 

pushing/pulling the train; or a caboose or car equipped with remote control equipment that 

provides an interface between the remote control transmitter (RCT) and a locomotive for remote 

control operation. Only those portions of the control cab locomotive that have appurtenances 

and items listed in part 229 have to be in compliance with part 229. 

Section (f): Dead Locomotive A dead locomotive can have the diesel engine either idling or 

shut down. It cannot supply tractive effort. It must be “off-line.” 

Section (k): Locomotive A hi-rail vehicle is defined as a truck, automobile, or machinery with 

retractable flanged wheels, so that it may be used on either the highway or railroad track. 

Specialized maintenance or other similar equipment includes track motor cars, cranes, derricks, 
Motive Power and Equipment Compliance Manual 

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pile drivers, rail grinders, ballast cleaners, etc. Periodically, FRA receives inquiries about 

equipment requirements for self-propelled vehicles used to haul revenue freight on the main line. 

These vehicles include those built by Trackmobile Inc., Shuttle Wagon, Mitchell Equipment 

Corporation and Brandt RoadRailer®. Self-propelled vehicles are used in a variety of railroad 

functions. When self-propelled vehicles are used only in the performance of typical 

maintenance-of-way functions, or if they are used to move cars or equipment within the confines 

of repair facilities, they are to be considered specialized maintenance equipment and are exempt 

from many FRA regulations. When a self-propelled vehicle is used to move freight over the 

railroad, outside the limits established for maintenance-of-way operations and repair facilities, it 

will be considered a locomotive and must comply with applicable regulations. Even though 

these vehicles do not resemble a standard locomotive, the purpose for which they are being used 

requires compliance with 49 CFR parts 223, 229, 231, and 232. The self-propelled vehicles are 

unique in construction, appearance, and use. 

Many of these vehicles currently being used have already been modified by the manufacturers 

(as closely as construction would permit) to bring them into compliance with Federal regulations. 

FRA acknowledges that this equipment has a place in a well-rounded rail transportation system. 

In an effort to recognize the unique characteristics of these vehicles, FRA inspectors should 

exercise enforcement discretion and good judgment in analyzing an operation where selfpropelled vehicles are used for train movements. Items deemed to be safety-related, that cannot 

meet specified requirements, will have to be addressed through the waiver process. The 

following specifications should be used by inspectors for enforcement guidance: 

1. The vehicle glazing material must comply with part 223. 

2. Each self-propelled vehicle shall be inspected each calendar day when used, and an 

inspection report and record shall be completed as described in section 229.21. 

3. Each self-propelled vehicle shall receive a periodic inspection as described in section 

229.23, and all pertinent data is to be entered on an FRA Form F6180.49A, Locomotive 

Inspection and Repair Report, which shall be displayed under a transparent cover in a 

conspicuous place in the cab of the vehicle. 

4. The vehicle’s air brake equipment must be cleaned and tested as often as conditions 

require, but not less frequently than required in sections 229.25, 229.27, and 229.29. 

5. The main air reservoir must comply with section 229.31 regarding either hammer and 

hydrostatic testing or pre-drilling of the reservoir. 

6. The vehicle must meet general safety requirements of sections 229.41, 229.43, and 

229.45. 

7. Fuel safety cut-off devices must follow Section 229.93. 
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8. The vehicle must have a speed indicator if it is operated at a speed that exceeds 20 mph 

according to section 229.117. 

9. Interior cab noise must comply with section 229.121. 

10. Vehicle headlights must be fully functional; and, if operated at speeds in excess of 20 

mph over one or more public highway-rail grade crossings, must comply with auxiliary 

light requirements according to section 229.125. 

11. The vehicle must be equipped with a horn according to section 229.129. 

12. If operated at speeds in excess of 30 mph while hauling cars, the vehicle must be 

equipped with working event recorder in compliance with section 229.135. 

13. Switching steps as defined in section 231.30. 

14. Four horizontal handholds shall be secured to the front and back ends of the vehicle, and 

shall be secured by bolts or other acceptable mechanical fastener (see Section 231.30). 

15. The vehicle should have vertical handholds painted in contrasting colors and secured by 

bolts or other acceptable fasteners in compliance with section 231.30. 

16. The vehicle must be equipped with automatic couplers, to prevent the necessity of 

someone going between the vehicle and car for the purpose of coupling or uncoupling in 

compliance with section 231.30. 

17. If conditions warrant, a two-way end-of-train device must be used in compliance with 

sections 232.401–232.409. 

18. As with any train movement, the vehicle must be equipped with a brake system that 

permits the operator to apply and release the brakes on cars being hauled. The brake 

equipment must also be arranged so that proper air brake leakage tests can be conducted 

as applicable in compliance with sections 232.12 and 232.13. (MP&E 98-71.)

Despite the fact that the Burro Crane is excluded from the definition of “locomotive” under § 

229.5(I) of the Locomotive Safety Standards as a piece of specialized maintenance equipment, 

and is not subject to those Standards, the Burro Crane is nevertheless subject to the statutory 

requirements of the Locomotive Inspection Act, in particular, the requirement that it is safe. In 

the preamble to the final locomotive rules, FRA explicitly recognizes the applicability of the Act 

by stating that “FRA will continue to implement the basic statutory safety requirements with 

respect to such work equipment by using the Special Notice when appropriate.” 45 FR 21093. 

(MP&E 98-25.) 

Section (l): MU Locomotive This refers to the self-propelled transit cars in commuter service in 

various large urban centers around the country. This section does not apply to the common 

vernacular of the railroad industry, whereby MU locomotive is a generic term given to any 
Motive Power and Equipment Compliance Manual 

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locomotive that can be coupled in a consist with other locomotives and controlled from a single 

control location. 

§ 229.7 Prohibited Acts. 

(a) The Locomotive Inspection Act (45 U.S.C. 22-34) makes it unlawful for any carrier to 

use or permit to be used on its line any locomotive unless the entire locomotive and its 

appurtenances – 

(1) Are in proper condition and safe to operate in the service to which they are 

put, without unnecessary peril to life or limb; and 

(2) Have been inspected and tested as required by this part. 

(b) Any person (an entity of any type covered under 1 U.S.C. 1, including but not limited 

to the following: a railroad; a manager, supervisor, official, or other employee or agent of 

a railroad; any owner, manufacturer, lessor, or lessee of railroad equipment, track, or 

facilities; any independent contractor providing goods or services to a railroad; and any 

employee of such owner, manufacturer, lessor, lessee, or independent contractor) who 

violates any requirement of this part or of the Locomotive Inspection Act or causes the 

violation of any such requirement is subject to a civil penalty of at least $500 and not 

more than $11,000 per violation, except that: Penalties may be assessed against 

individuals only for willful violations, and, where a grossly negligent violation or a 

pattern of repeated violations has created an imminent hazard of death or injury to 

persons, or has caused death or injury, a penalty not to exceed $22,000 per violation may 

be assessed. Each day a violation continues shall constitute a separate offense. See 

appendix B to this part for a statement of agency civil penalty policy. 

Guidance 

Paragraph (a) of this section is the regulatory codification of the general statutory language 

previously contained in the Locomotive Inspection Act, re-codified at 49 U.S.C. § 20701. This 

section should only be cited when defective conditions of a locomotive’s appurtenances are 

disclosed on items not specifically covered by other provisions contained in part 229. For 

example, this provision should be used to report a defective appurtenance such as a warning bell 

or alerter equipment. Defective equipment associated with remote control locomotive (RCL) 

operations should be addressed under this section. The remote control transmitter (RCT), when 

operating a locomotive in remote mode, becomes an appurtenance to that locomotive and is 

subject to the provisions of this section. Also, any lights added to an RCL that indicate the 

locomotive is operating in the remote control mode is an appurtenance. Therefore, if any of the 

equipment associated with RCL operations is found defective at any time during remote mode 

operation, appropriate enforcement action should be taken. 

The inspector may consider filing a violation under this section if the following is evident: 
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1. The locomotive is not in safe or proper condition for the service in which it will be 

placed. 

2. The involved condition endangers the railroad personnel and/or the public by exposing 

them to unnecessary peril to life or limb. 

If an inspector seeks a violation under this provision, the inspector must fully describe the 

defective part or appurtenance, and must fully explain how the defective part or appurtenance 

endangers the safety of the crew and/or the general public. This section should not be cited if the 

condition or defective appurtenance is specifically addressed in another provision contained in 

part 229, the more specific provision should be used. 

Paragraph (b) of this section recognizes FRA’s ability to use individual liability as an 

enforcement tool in circumstances where a railroad employee willfully allows the use of a 

locomotive with a noncomplying condition covered by this part. Inspectors must exercise care in 

these circumstances, ensuring that all the concerns and guidelines discussed in Chapter 3 of this 

manual and in Appendix A to 49 CFR part 209 are followed and addressed before pursuing 

enforcement action against an individual. 

§ 229.9 Movement of non-complying locomotives. 

(a) Except as provided in paragraphs (b), (c) and § 229.125(h), a locomotive with one or 

more conditions not in compliance with this part may be moved only as a lite locomotive 

or a dead locomotive after the carrier has complied with the following: 

 (1) A qualified person shall determine – 

(i) That it is safe to move the locomotive; and 

(ii) The maximum speed and other restrictions necessary for safely 

conducting the movement; 

(2) (i) The engineer in charge of the movement of the locomotive shall be 

notified in writing and inform all other crew members in the cab of the 

presence of the non-complying locomotive and the maximum speed and 

other restrictions determined under paragraph (a)(1)(ii) of this section. 

(ii) A copy of the tag described in paragraph (a)(3) of this section may be 

used to provide the notification required by paragraph (a)(2)(I) of this 

section. 

(3) A tag bearing the words “non-complying locomotive” and containing the 

following information, shall be securely attached to the control stand on each MU 

or control cab locomotive and to the isolation switch or near the engine start 

switch on every other type of locomotive – 
Motive Power and Equipment Compliance Manual 

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(i) The locomotive number; 

(ii) The name of the inspecting carrier; 

(iii) The inspection location and date; 

(iv) The nature of each defect; 

(v) Movement restrictions, if any; 

(vi) The destination; and 

(vii) The signature of the person making the determinations required by 

this paragraph. 

(b) A locomotive that develops a non-complying condition enroute may continue to 

utilize its propelling motors, if the requirements of paragraph (a) are otherwise fully met, 

until the earlier of – 

 

(1) The next calendar day inspection, or 

(2) The nearest forward point where the repairs necessary to bring it into 

compliance can be made. 

(c) A non-complying locomotive may be moved lite or dead within a yard, at speeds not 

in excess of 10 miles per hour, without meeting the requirements of paragraph (a) of this 

section if the movement is solely for the purpose of repair. The carrier is responsible to 

insure that the movement may be safely made. 

(d) A dead locomotive may not continue in use following a calendar day inspection as a 

controlling locomotive or at the head of a train or locomotive consist. 

(e) A locomotive does not cease to be a locomotive because its propelling motor or 

motors are inoperative or because its control jumper cables are not connected. 

(f) Nothing in this section authorizes the movement of a locomotive subject to a Special 

Notice for Repair unless the movement is made in accordance with the restrictions 

contained in the Special Notice. 

(g) Paragraphs (a), (b), (c) of this section shall not apply to sanitation conditions covered 

by §§ 229.137 and 229.139. Sections 229.137 and 229.139 set forth specific 

requirements for the movement and repair of locomotives with defective sanitation 

compartments. 

Guidance 
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Section (a): When a noncomplying condition under part 229 is found by either the railroad’s 

inspector or an MP&E inspector (except as provided in paragraphs (b) and (c)), the railroad may 

only move the locomotive as a lite locomotive or dead locomotive under whatever conditions 

that the qualified person and the railroad deem suitable for a safe move (except as provided in 

paragraphs (b) and (c)). The locomotive may be moved to any location the railroad designates to 

have it brought into compliance. If the FRA inspector believes that the movement of the 

locomotive by the railroad under this section constitutes an immediately unsafe situation (such as 

possible derailment) a Special Notice for Repairs, FRA Form F6180.8, may be issued to 

effectively remove the locomotive from service. In addition to describing the immediate unsafe 

condition, the inspector must also note that the movement restrictions or lack of (e.g., speed, 

distance, etc.), as proposed by the railroad, would create an additional unsafe problem. The 

inspector should never dictate to a railroad conditions for the movement of any noncomplying 

locomotive, unless the condition is so deplorable that movement at any speed would create an 

unsafe condition. Any restrictions are the railroad’s responsibility. 

Section (b) allows for the continued use of a locomotive that develops an en route noncomplying 

condition until the earlier of (1) the next calendar-day inspection, or (2) the nearest forward point 

where the repairs necessary to bring it into compliance can be made. Use of a locomotive under 

this provision is permitted only if the requirements of § 229.9(a) are fully met, which means a 

“noncomplying tag” that is properly filled out must be in the cab of the noncomplying 

locomotive. 

If the noncomplying condition can be brought into compliance by shifting the position of the 

locomotive in the consist, the noncomplying condition should be rectified by doing so at the next 

forward location where this can be accomplished. This could be a siding, a wye, or any location 

where it is physically possible to reposition the locomotive. Railroad employees performing this 

task may do so if it does not endanger the safety of the employees, locomotives, or trains. This 

location should not be construed or designated as a repair point. 

Section (a)(1) requires that, “A qualified person shall determine - (i) That it is safe to move the 

locomotive; and (ii) The maximum speed and other restrictions necessary for safely conducting 

the movement. “Difficulty in the interpretation and enforcement of Section 229.9 arises as this 

section does not provide guidance with respect to the criteria used to “qualify” a person to make 

the determination required above. The decisions to continue the use of a noncomplying 

locomotive in some cases are being made by persons not qualified to make these decisions. A 

person qualified to perform a daily inspection may not necessarily possess the qualifications to 

make the determination that it is safe to move a defective locomotive. 

The qualified person must have demonstrated to the railroad, at a minimum, the knowledge and 

ability to inspect locomotives and provide recommendations regarding the criteria listed in 

Section (a). This does not imply that the qualified person must possess intimate knowledge of 

and experience with all of the components and functions of a locomotive. Additionally, there are 

varying levels of qualified persons. As an example, a journeyman electrician may not have the 

necessary knowledge to make safety recommendations concerning locomotive running gear. 
Motive Power and Equipment Compliance Manual 

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However, that person should be qualified to address problems associated with the electric control 

apparatus. 

Section 240.123 requires that each railroad provide for initial and continuing education of 

certified locomotive engineers to ensure that each engineer maintains the knowledge, skills, and 

ability with respect to (among other areas) the mechanical condition of equipment. As such, the 

locomotive engineer is considered qualified to provide safety recommendations concerning 

certain en route noncomplying conditions. Normally, these conditions are limited to those that 

are evaluated during the daily inspection required by Section 229.21, such as headlights, speed 

indicators, cab seats, air brakes, wipers, and alerter malfunctions. The locomotive engineer 

would also be expected to identify certain obvious mechanical problems such as major wheel 

defects and some running gear problems. However, the engineer would not be expected to 

properly assess the safety implications of continued movement of the locomotive for most 

mechanical defects. In these cases, recommendations regarding the continued safe movement of 

a noncomplying locomotive (in accordance with § 229.9(a)(1)) need to be made by a person that 

is more qualified, such as a mechanical department employee. These recommendations may be 

based on telephone or radio conversations between the engineer and the more qualified 

individual. If the noncomplying condition cannot be resolved solely via voice communication, a 

qualified individual must conduct a physical onsite inspection to identify all appropriate 

restrictions for continued safe movement of the locomotive. 

While it is the transportation/operating department that controls the daily operation of the 

railroad, operating personnel may not possess the qualifications and technical expertise to make 

safety recommendations regarding noncomplying locomotives. When investigating an issue 

involving enforcement of § 229.9, MP&E inspectors must carefully examine the qualifications of 

the individual who made the safety recommendations to determine if the railroad acted in 

compliance with the regulations. 

Certain noncomplying conditions require a locomotive to be removed from the lead position at 

the first available location, but would not require it to be removed from service. Examples of 

such conditions include, but are not limited to: speed indicators, headlights, cab windows, and 

audible warning devices. When conditions such as these exist, the railroad must, in order to be 

in compliance, remove the locomotive from the lead position. Inspectors must exercise sound 

judgment. For example, a defective cab heater during warm weather would not necessitate 

removal of the locomotive from the lead or controlling position. In the interest of safety, when a 

locomotive is repositioned from the lead position to correct a noncomplying condition, the 

“noncomplying locomotive tag” should remain attached to the locomotive until repairs are made. 

Section 229.9 is silent on the repair location question. It depends on the power penalty built into 

the regulation to convince the railroad to maintain the locomotive fleet. Movement of a lite or 

dead locomotive not only limits the power available, but adds tonnage to the train. 

Where an MP&E inspector has knowledge that a railroad permits locomotives (that develop 

noncomplying conditions en route) to continue in service past mechanical facilities where repairs 

can be made, he/she should investigate to determine that the railroad is complying with the 

requirements of Section (a). If the inspector is made aware that a noncomplying locomotive was 
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moved beyond a forward repair location that has previously demonstrated the ability to effect 

repairs of the noncomplying condition, he or she must ensure that the subject locomotive would 

no longer be used as a propelling or lead locomotive. There is no implication in subsection (b) 

that each repair location must be capable of repairing all en route noncomplying conditions that 

can occur. 

Section 229.9 allows a railroad to move a noncomplying locomotive as a lite or dead locomotive 

to a more distant repair point of its choice, provided it meets all other requirements of § 229.9 

and such action does not endanger the safety of employees, locomotives, or trains. 

Section 229.9 only permits the movement of a noncomplying locomotive with a part 229 defect. 

Nothing in § 229.9 authorizes the movement of a locomotive with power brake or safety 

appliance defects. Such locomotives can only be moved under provisions of Section 20303 of 

the Public Law 103-272 (July 5, 1994) and/or the Power Brake Regulations. (MP&E 98-50) It 

is the responsibility of the railroad to ensure that any locomotive that is moved with a 

noncomplying defect is in accordance with the applicable law. If there is any doubt, the railroad 

should contact FRA. The move may require the railroad to submit for one-time movement 

authority. (See Chapter 2) 

Subsection (d) restricts the use of a dead locomotive as a controlling locomotive following a 

calendar-day inspection. If a noncomplying condition occurs en route that renders the 

locomotive dead, it can continue to control the locomotive consist until a daily inspection is 

performed. The intent of this restriction is to ensure that crew members are not permitted or 

required to occupy the cab of a noncomplying locomotive over an extended period of time. 

Section (e) means that a locomotive is a locomotive at all times and must be in full compliance 

when in service or tagged as required by Section 229.9(a). 

§ 229.11 Locomotive Identification. 

(a) The letter “F” shall be legibly shown on each side of every locomotive near the end 

which for identification purposes will be known as the front end. 

(b) The locomotive number shall be displayed in clearly legible numbers on each side of 

each locomotive. 

Guidance 

If vandals have painted graffiti on the locomotive and obscured the identification marks, the 

inspector should point the defect out to the railroad and use appropriate discretion to gain 

compliance. Railroad initials do not have to be clearly legible on a locomotive. The regulation 

does not require railroad initials, only a number. 

The “F” is very important in remote control locomotive operations. 

§ 229.13 Control of locomotives. 
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Except when a locomotive is moved in accordance with § 229.9, whenever two or more 

locomotives are coupled in remote or multiple control, the propulsion system, the sanders, and 

the power brake system of each locomotive shall respond to control from the cab of the 

controlling locomotive. If a dynamic brake or regenerative brake system is in use, that portion of 

the system in use shall respond to control from the cab of the controlling locomotive. 

Guidance 

This requirement also applies to controls of distributed power locomotives (DPU), which are 

controlled from a lead locomotive by either a radio signal, or an electrical signal through a hard 

wire. This also applies when a locomotive consist is operated via remote control, using a belt 

pack. The belt pack is treated the same as the cab of the controlling locomotive when remote 

control locomotive operation is in effect. 

§ 229.14 Non-MU locomotive control cab locomotives. 

On each non-MU control cab locomotive, only those components added to the passenger car that 

enable it to serve as a lead locomotive, control the locomotive actually providing tractive power, 

and otherwise control the movement of the train, are subject to this part. 

Guidance 

Only those components added to a passenger car or an “RCL caboose” that make it function as a 

locomotive (e.g., the controller, speed indicator, etc.), related to controlling speed and braking of 

a train, are subject to this part. 

§ 229.17 Accident reports. 

§ 229.19 Prior Waivers 

§ 229.21 Daily Inspection. 

(a) Except for MU locomotives, each locomotive in use shall be inspected at least once 

during each calendar day. A written report of the inspection shall be made. This report 

shall contain the name of the carrier; the initials and number of the locomotive; the place, 

date and time of the inspection; a description of the non-complying conditions disclosed 

by the inspection; and the signature of the employee making the inspection. Except as 

provided in §§ 229.9, 229.137, 229.139, any conditions that constitute non-compliance 

with any requirement of this part shall be repaired before the locomotive is used. Except 

with respect to conditions that do not comply with § 229.137 or § 229.139, a notation 

shall be made on the report indicating the nature of the repairs that have been made. 

Repairs made for conditions that do not comply with § 229.137 or § 229.139 may be 

noted on the report, or in electronic form. The person making the repairs shall sign the 

report. The report shall be filed and retained for at least 92 days in the office of the carrier 
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at the terminal at which the locomotive is cared for. A record shall be maintained on each 

locomotive showing the place, date and time of the previous inspection. 

(b) Each MU locomotive in use shall be inspected at least once during each calendar day 

and a written report of the inspection shall be made. This report may be part of a single 

master report covering an entire group of MU’s. If any non-complying conditions are 

found, a separate, individual report shall be made containing the name of the carrier; the 

initials and number of the locomotive; the place, date, and time of the inspection; the 

non-complying conditions found; and the signature of the inspector. Except as provided 

in §§ 229.9, 229.137, 229.139, any conditions that constitute non-compliance with any 

requirement of this part shall be repaired before the locomotive is used. Except with 

respect to conditions that do not comply with § 229.137 or § 229.139, a notation shall be 

made on the report indicating the nature of the repairs that have been made. Repairs 

made for conditions that do not comply with § 229.137 or § 229.139 may be noted on the 

report, or in electronic form. The person making the repairs shall sign the report. The 

report shall be filed in the office of the carrier at the place where the inspection is made 

or at one central location and retained for at least 92 days. 

(c) Each carrier shall designate qualified persons to make the inspections required by this 

section. 

Guidance

The purpose of the calendar-day inspection is to ascertain that the locomotive is safe to operate 

in the service for which it is used, and is in total compliance with part 229 prior to being placed 

in service. It is a visual walk-around inspection of the locomotive that provides an opportunity, 

every day the locomotive is used, to find and correct incipient problems before they lead to an 

accident or safety incident. An effective locomotive calendar-day inspection requires that the 

individual performing the inspection be alert for telltale signs of any condition or defect that is a 

potential hazard. 

After a daily inspection is performed, the locomotive should be free of any noncomplying 

conditions before it is offered for service. The locomotive cannot legally be used until all 

Federal defects are corrected. 

If the inspector continues to find recurrent defects or a pattern of noncomplying conditions at a 

particular location, he/she should monitor the performance and the results of the daily 

inspections, as well as question the individual(s) performing the inspections, to ascertain if the 

individual(s) has the knowledge and ability to perform such inspections. 

If daily inspection reports reflect noncomplying conditions on a locomotive and the inspector 

finds the conditions were not corrected by the railroad, and the locomotive continues to be used, 

violations should be submitted. Such violations should be accompanied by all of the 

documentation available, with a complete explanation regarding the railroad operation at the 

location. 
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Failure to complete, or produce a record or report, in and of itself is not sufficient evidence to 

establish that a railroad failed to perform an inspection. It is a “records” violation, unless other 

evidence (e.g., witness statements, interviews, event recorder downloads, visual observations, 

etc.) is obtained to establish the failure to conduct the inspection. If the only evidence available 

merely establishes a failure to complete the cab card or a failure of a railroad to produce a 

required inspection report, then the appropriate section to cite for civil penalty is § 229.21(a)(2), 

Report not properly executed or retained. Use the “lack of a record and/or report” to support the 

other evidence obtained to establish a “failure to perform an inspection” violation. 

Section (a): A daily inspection is required by this section for each day a locomotive is in use. A 

written report and record are required when the inspection is performed. The inspection can be 

conducted at any time during the calendar day. It can be done just before midnight or just after 

midnight. If an inspection were performed just after midnight, the locomotive can be legally 

used for almost 48 hours before the next inspection is required. An inspection is not needed 

unless the locomotive is used during the calendar day. If a locomotive completes an assignment 

prior to the expiration of the calendar day and is not returned to service for several days, it would 

need a daily inspection before midnight of the day it is put back into service. This regulation has 

a number of ambiguities that each inspector must be aware of when judging the inspection status 

of any given locomotive. 

 

Sections (a) and (b): The inspection reports are to be filed and retained for 92 days at the 

terminal where the locomotive is maintained. FRA allows railroads to keep the reports at a 

central location, and waivers have been granted to individual railroads that allow for these 

reports to be electronically generated and kept. Whether it is a written or electronic report, it 

must contain the name of the railroad; initial and number of the locomotive; the place, date, and 

time of the inspection; a description of any noncomplying conditions; and the signature of the 

inspector. An inspector has the right to request the reports for a specific locomotive(s) for the 

past 92 days and the railroad is obligated to provide such reports in a timely manner. A written 

or electronic record of the previous inspection must be physically kept on each locomotive until 

the next inspection is performed. The record must contain the place, date, and time of the 

previous inspection. 

FRA has determined that § 229.21(a) permits railroads to make either a single written report for 

each locomotive inspected or a single written report that covers multiple locomotives (usually an 

entire consist); provided, the report contains the necessary information and is properly retained 

as indicated below. 

When FRA proposed and adopted the locomotive inspection reporting requirements currently 

contained in § 229.21(a), FRA specifically eliminated the previously existing requirement for an 

approved reporting form. (See 44 FR 29613, May 21, 1979) When proposing the existing 

reporting requirements, FRA specifically stated that a railroad could adopt any type of written 

report as long as it included the required information. (See 44 FR 29613) Consequently, FRA 

will permit railroads to use a single written report that covers multiple locomotives to meet the 

written reporting requirements contained in § 229.21(a). However, in order to ensure that all of 

the required information is contained on such reports and to ensure their proper retention, the 
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following conditions must be met if multiple locomotives are addressed on a single daily 

inspection report: 

(a) Each multiple locomotive daily inspection report provides a space for the initials and 

number of each locomotive inspected; the place, date, and time of the inspection; and the 

signature of inspector. 

(b) The inspection report contains a space for entering the initial and number of each 

noncomplying locomotive adjacent to the noncomplying condition(s) disclosed by the 

inspection. There also must be a space to enter the corrective action(s) taken and the 

signature of person making the repairs. 

(c) A copy of the multiple locomotives inspection report is made for each locomotive 

entered on the report and retained for at least 92 days at a location designated by the 

railroad. 

(d) A written record is maintained on each locomotive, indicating the date, time and 

location of the previous calendar-day inspection. 

(e) Any condition that constitutes noncompliance with any requirement contained in part 

229, Locomotive Safety Standards, is repaired before the locomotive is used, or the 

locomotive must be tagged and moved in accordance with § 229.9. 

When performing records inspections, the FRA inspectors should review the railroad’s calendarday inspection report procedures. If the FRA inspectors make a request for inspection reports, 

and the railroad is unable to provide a copy for each individual locomotive, appropriate 

enforcement action should be taken. (MP&E 00-04)

Section (c): This section gives the railroad sole prerogative to designate qualified persons to 

perform the required inspections. FRA has not set forth any qualification standards for the 

railroad’s designated inspector. 

Inspectors should consider issuing a violation report if any of the following questions are 

answered in the affirmative: 

(a) Were noncomplying conditions previously reported on the calendar-day inspection 

report not repaired? 

(b) Does the railroad have a history of ignoring the requirements of the calendar-day 

inspection regulation? 

(c) Can a violation be documented from railroad records for the use of a locomotive 

overdue calendar-day inspection? 

(d) Does the overdue inspection create an immediate hazard? 
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If an inspector finds a locomotive being used, with multiple, obvious defects after it just received 

an inspection, a violation can be submitted for both the defective condition(s) and failure to 

perform a proper inspection. 

 

Remote Control Locomotive (RCL) 

A locomotive operating as a RCL is given the same daily inspection as a conventional 

locomotive. The only difference between the two would be the operating controls. If the 

locomotive is operating in manual mode during the inspection, the brakes would be tested from 

the controls of the locomotive. If the locomotive is operating in remote mode during the 

inspection, the brakes would be tested from the remote control transmitter (RCT). Additionally, 

all features on the RCT would be tested to determine that they are functioning properly. 

If the RCL received its daily inspection when the locomotive was operating in the manual mode, 

and later a crew links the RCT to operate the locomotive in remote mode, the transmitter must be 

tested to determine that it functions as intended prior to commencing remote control operations. 

No additional reporting is required, with regards to the daily inspection report. 

The RCT, when operating the locomotive, becomes an appurtenance to that locomotive and is 

subject to the provisions of Section 229.7. Therefore, if an RCT is found to be defective during 

the calendar-day inspection, it may not be used. Since the transmitter is not permanently 

mounted to the locomotive, if found to be defective it can be removed from service and another 

RCT can be linked to the locomotive after receiving a proper test and inspection. 

If the RCL equipment that is permanently mounted to the locomotive becomes defective, the 

defect and repairs made must be noted on the locomotive daily inspection report. RCTs are 

portable and are interchangeable. If the transmitter is found to be defective, it does not affect the 

locomotive if the locomotive can still be operated manually or another transmitter can be linked 

to the RCL. Since the RCT can operate with several locomotives, the defective transmitter does 

not need to be reported on the locomotive inspection report. To satisfy the requirement to tag 

and track defective equipment (49 CFR § 229.21), the railroad should develop a means to (1) 

readily identify defective RCTs, (2) record defective conditions, (3) indicate repairs made, (4) 

name the person making the repairs, and (5) maintain that record for 92 days. 

The requirement to maintain the onboard record does not change. If the RCT is inspected and 

tested as part of the daily inspection, the onboard record is inclusive of this. If the RCT is added 

to the locomotive some time after the daily inspection, the device must be tested and inspected to 

ensure that the brakes, throttle, and all safety features function as intended. (MP&E 02-01)

§ 229.23 Periodic Inspection: General. 

(a) Each locomotive and steam generator shall be inspected at each periodic inspection to 

determine whether it complies with this part. Except as provided in § 229.9, all noncomplying conditions shall be repaired before the locomotive or the steam generator is 

used. Except as provided in § 229.33, the interval between any two periodic inspections 

may not exceed 92 days. Periodic inspections shall only be made where adequate 
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facilities are available. At each periodic inspection, a locomotive shall be positioned so 

that a person may safely inspect the entire underneath portion of the locomotive. 

(b) The periodic inspection of the steam generator may be postponed indefinitely if the 

water suction pipe to the water pump and the leads to the main switch (steam generator 

switch) are disconnected, and the train line shut-off-valve is wired closed or a blind 

gasket applied. However, the steam generator shall be so inspected before it is returned to 

use. 

(c) After April 30, 1980, each new locomotive shall receive an initial periodic inspection 

before it is used. Except as provided in § 229.33, each locomotive in use on or before 

April 30, 1980, shall receive an initial periodic inspection within 92 days of the last 30-

day inspection performed under the prior rules (49 CFR 230.331 and 230.451). At the 

initial periodic inspection, the date and place of the last tests performed that are the 

equivalent of the tests required by §§ 229.27, 229.29, and 229.31 shall be entered on 

Form FRA F 6180-49A. These dates shall determine when the tests first become due 

under §§ 229.27, 229.29, and 229.31. Out of use credit may be carried over from Form 

FRA F 6180-49 and entered on Form FRA F 6180-49A. 

(d) Each periodic inspection shall be recorded on Form FRA F 6180-49A. The form shall 

be signed by the person conducting the inspection and certified by that person’s 

supervisor that the work was done. The form shall be displayed under a transparent cover 

in a conspicuous place in the cab of each locomotive. 

(e) At the first periodic inspection in each calendar year the carrier shall remove from 

each locomotive Form FRA F 6180-49A covering the previous calendar year. If a 

locomotive does not receive its first periodic inspection in a calendar year before April 2 

because it is out of use, the form shall be promptly replaced. The Form FRA F 6180-49A 

covering the preceding year for each locomotive, in or out of use, shall be signed by the 

railroad official responsible for the locomotive and filed as required in § 229.23(f). The 

date and place of the last periodic inspection and the date and place of the last test 

performed under §§ 229.27, 229.29, and 229.31 shall be transferred to the replacement 

Form FRA F6180-49A. 

(f) The mechanical officer of each railroad who is in charge of a locomotive shall 

maintain in his office a secondary record of the information reported on Form FRA F 

6180-49A under this part. The secondary record shall be retained until Form FRA F 

6180-49A has been removed from the locomotive and filed in the railroad office of the 

mechanical officer in charge of the locomotive. If the Form FRA F 6180-49A removed 

from the locomotive is not clearly legible, the secondary record shall be retained until the 

Form FRA F 6180-49A for the succeeding year is filed. The Form F 6180-49A removed 

from a locomotive shall be retained until the Form FRA F 6180-49A for the succeeding 

year is filed. 

Guidance
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Section (a): The 92-day cycle begins (day 1) on the date entered on FRA Form F6180.49A. The 

92-day cycle ends 11:59 p.m. on day 92, unless there is legitimate out-of-service time as defined 

in § 229.33. Some Class 1 railroads are performing inspections and reporting them on the FRA 

Form F6180.49A report at intervals shorter than 92 days. FRA takes no exception to this 

practice but the inspector should take sufficient time to examine the report to determine that all 

tests have been performed within the required time periods. The term “adequate facilities” is 

deliberately not spelled out in the regulation. The regulation does not mandate that a pit is 

required, but it must be possible to thoroughly inspect the underneath portion of the locomotive 

safely. This allows small shortline railroads, which may not have a pit, the flexibility to place or 

arrange a locomotive in some position or location so that a person can safely inspect under the 

locomotive. 

Section (b): This section, for all practical purposes, is obsolete given that all of the passenger 

trains used by Amtrak and the commuter railroads use head end electric power for heating their 

trains. There may be some steam generators in use on the trains used on some seasonal tourist or 

historical operations. 

 

Section (d): The FRA Form F6180.49A must be signed by the worker performing the inspection 

and the supervisor in charge of the workers. A signature is required. On some small railroad 

operations, the owner, supervisor, and worker may be one individual. Therefore, one individual 

would sign as the worker and the supervisor. 

Some railroads have gone to a computer-generated FRA Form F6180.49A, which is replaced at 

each periodic inspection. This form must bear the original signatures of the personnel involved 

with the most recent inspection and tests. The computer-generated form and the form used at 

intervals of less than 92 days will require inspectors to spend more time to determine if the 

locomotive is in compliance with time elements in §§ 229.23, 229.25, and 229.27. 

If an inspector finds locomotives without an FRA Form F6180.49A displayed in the locomotive 

cab, he/she shall make inquiry of the railroad as to the reason. If the inspector is satisfied with 

the railroad’s backup records and the form was lost or destroyed, the railroad is allowed to fax a 

copy of the form to be placed on the locomotive. The faxed copy would have to be legible, with 

all pertinent information and signatures. 

Section (f): Unless requested, a railroad does not have to forward an FRA Form F6180.49A to 

the Washington, DC, Office of Safety Assurance and Compliance. 

Periodic Inspections – Locomotives that operate outside of the United States 

With the increase of railroad traffic at both the U.S./Canadian border and the U.S./Mexican 

border, inspectors should be governed by the following information relative to required daily and 

periodic inspections and tests for locomotives. 

Locomotives that operate outside of the United States are governed by the laws of the country 

where they operate. Neither Canada nor Mexico requires the types of inspections that are 

commensurate with the tests and inspections described in Sections 229.21, 229.23, 229.25, 
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229.27, and 229.29. However, FRA requires that all locomotives that operate in the United 

States must be in full compliance with Federal laws and regulations. 

Therefore, FRA requires that all locomotives entering the United States from either Canada or 

Mexico must not be used until all the tests and inspections required by Section 229.21, et al., 

have been completed and properly recorded. Those inspections and tests must be done either at 

the point of entry into the United States, or arranged to be done within Canada or Mexico, prior 

to entry into this country. If the inspections and tests are not properly performed and/or the 

locomotive is not in compliance with FRA regulations upon entry into the United States, the 

locomotive may be moved only under the provisions of Section 229.9 as a dead or lite 

locomotive. (MP&E 98-37)

§ 229.25 Tests: Every Periodic Inspection. 

Each periodic inspection shall include the following: 

(a) All mechanical gauges used by the engineer to aid in the control or braking of the 

train or locomotive, except load meters used in conjunction with an auxiliary brake 

system, shall be tested by comparison with a dead-weight tester or a test gauge designed 

for this purpose. 

(b) All electrical devices and visible insulation shall be inspected. 

(c) All cable connections between locomotives and jumpers that are designed to carry 

600 volts or more shall be thoroughly cleaned, inspected, and tested for continuity. 

(d) Each steam generator that is not isolated as prescribed in § 229.23(b) shall be 

inspected and tested as follows: 

(1) All automatic controls, alarms and protective devices shall be inspected and 

tested. 

(2) Steam pressure gauges shall be tested by comparison with a dead-weight tester 

or a test gauge designed for this purpose. The siphons to the steam gauges shall be 

removed and their connections examined to determine that they are open. 

(3) Safety valves shall be set and tested under steam after the steam pressure 

gauge is tested. 

(e) Event Recorder. A microprocessor-based self-monitoring event recorder, if installed, 

is exempt from periodic inspection under paragraphs (e)(1) through (e)(5) of this section 

and shall be inspected annually as required by § 229.27(d). Other types of event 

recorders, if installed, shall be inspected, maintained, and tested in accordance with 

instructions of the manufacturer, supplier, or owner thereof and in accordance with the 

following criteria: 
Motive Power and Equipment Compliance Manual 

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(1) A written or electronic copy of the instructions in use shall be kept at the 

point where the work is performed and a hard-copy version, written in the English 

language, shall be made available upon request of a governmental agent 

empowered to request it. 

(2) The event recorder shall be tested before any maintenance work is performed 

on it. At a minimum, the event recorder test shall include cycling, as practicable, 

all required recording elements and determining the full range of each element by 

reading out recorded data. 

(3) If the pre-maintenance test does not reveal that the device is recording all the 

specified data and that all recordings are within the designed recording elements, 

this fact shall be noted, and maintenance and testing shall be performed as 

necessary until a subsequent test is successful. 

(4) When a successful test is accomplished, a copy of the data-verification results 

shall be maintained in any medium with the maintenance records for the 

locomotive until the next one is filed. 

(5) A railroad’s event recorder periodic maintenance shall be considered effective 

if 90 percent (90%) of the recorders on locomotives inbound for periodic 

inspection in any given calendar month are still fully functional; maintenance 

practices and test intervals shall be adjusted as necessary to yield effective 

periodic maintenance. 

Guidance 

Section (a): Many railroads use a portable air gauge test device that allows testing without 

removal of the gauges. The use of such a device is acceptable as long as the gauge is tested 

throughout its entire range. These requirements do not apply to electronic displays, as they are 

checked annually. 

Section (b): Sufficient inspection covers are to be removed from traction motors, traction 

generators, and electrical cabinets in order to thoroughly inspect such equipment for general 

safety conditions and safety defects. 

Section (e): Inspectors are advised to inquire about and monitor the periodic inspection, 

maintenance practices, and test intervals used by the railroads for event recorders when 

performing routine inspections at locomotive facilities. (MP&E 98-2) 

1. Requires replacement, by October 1, 2009, of each event recorder using magnetic 

tape as a storage medium with a certified crashworthy event recorder memory module 

(ERMM) capable of recording at least the same data elements as the recorder it replaces. 

Any magnetic tape recorder replaced after October 1, 2005, must be replaced with a 

certified crashworthy event recorder memory module. 
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2. Requires all new lead locomotives, lead manned helper locomotives, and controlling 

distributive power locomotives (ordered after October 1, 2006, or placed in service after 

October 1, 2009) to be equipped with a certified crashworthy ERMM capable of 

recording up to 25 data elements for traditional locomotives and 22 data elements for MU 

and DMU locomotives. 

3. Requires all remanufactured locomotives after October 1, 2007, to be equipped with a 

certified crashworthy ERMM capable of recording at least the same data elements as the 

event recorder on that locomotive prior to remanufacture. 

4. Requires event recorders originally manufactured after January 1, 2010, and installed 

on a covered locomotive, to be equipped with a certified crashworthy ERMM. 

5. Contains specific performance criteria for determining the crashworthiness of an 

ERMM. This includes criteria for fire, impact shock, static crush, fluid immersion, and 

hydrostatic pressure; and contains testing sequence requirements. The criteria are based 

on existing crashworthiness standards of the Institute of Electrical and Electronics 

Engineers, Inc. (IEEE), modified for the locomotive environment. 

6. Requires preservation of event recorder data for a period of 1 year for any locomotive 

involved in an accident or incident required to be reported to FRA under part 225. 

7. Provides relief from the periodic inspection requirements for microprocessor-based 

event recorders with self-monitoring features. Requires inspection of these types of event 

recorders annually. 

§ 229.27 Annual tests. 

A locomotive, except for a DMU or MU locomotive, shall be subjected to the tests and 

inspections prescribed in paragraphs (a), (b), and (c) of this section. A DMU locomotive and an 

MU locomotive shall be subjected to the tests and inspections prescribed in paragraphs (b) and 

(c) of this section. A locomotive, including a DMU locomotive and an MU locomotive, 

equipped with a microprocessor-based event recorder that includes a self-monitoring feature, 

shall be subjected to the tests and inspections prescribed in paragraph (d) of this section, at 

intervals that do not exceed 368 calendar days. 

(a)(1) The filtering devices or dirt collectors located in the main reservoir supply line to 

the air brake system shall be cleaned, repaired, or replaced. 

(2) Brake cylinder relay valve portions, main reservoir safety valves, brake pipe 

vent valve portions, feed and reducing valve portions in the air brake system 

(including related dirt collectors and filters) shall be cleaned, repaired, and tested. 

(3) The date and place of the cleaning, repairing, and testing shall be recorded on 

Form FRA F 6180-49A and the person performing the work and that person’s 

supervisor shall sign the form. A record of the parts of the air brake system that 
Motive Power and Equipment Compliance Manual 

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are cleaned, repaired, and tested shall be kept in the carrier’s files or in the cab of 

the locomotive. 

(4) At its option, a carrier may fragment the work required by this paragraph. In 

that event, a separate air record shall be maintained under a transparent cover in 

the cab. The air record shall include the locomotive number, a list of the air brake 

components, and the date and place of the last inspection and test of each 

component. The signature of the person performing the work and the signature of 

that person’s supervisor shall be included for each component. A duplicate record 

shall be maintained in the carrier’s files. 

(b) The load meter shall be tested. Each device used by the engineer to aid in the control 

or braking of the train or locomotive that provides an indication of air pressure 

electronically shall be tested by comparison with a test gauge or self-test designed for this 

purpose. An error of greater than five percent or three pounds per square inch shall be 

corrected. The date and place of the test shall be recorded on Form FRA F 6180-49A and 

the person conducting the test and that person’s supervisor shall sign the form. 

(c) Each steam generator that is not isolated as prescribed in § 229.23(b), shall be 

subjected to a hydrostatic pressure at least 25 percent above the working pressure and the 

visual return water-flow indicator shall be removed and inspected. 

(d) A microprocessor-based event recorder with a self-monitoring feature equipped to 

verify that all data elements required by this part are recorded, requires further 

maintenance only if either or both of the following conditions exist: 

(1) The self-monitoring feature displays an indication of a failure. If a failure is 

displayed, further maintenance and testing must be performed until a subsequent 

test is successful. When a successful test is accomplished, a record, in any 

medium, shall be made of that fact and of any maintenance work necessary to 

achieve the successful result. This record shall be available at the location where 

the locomotive is maintained until a record of a subsequent successful test is filed. 

(2)A download of the event recorder, taken within the preceding 30 days and 

reviewed for the previous 48 hours of locomotive operation, reveals a failure to 

record a regularly recurring data element or reveals that any required data element 

is not representative of the actual operations of the locomotive during this time 

period. If the review is not successful, further maintenance and testing shall be 

performed until a subsequent test is successful. When a successful test is 

accomplished, a record, in any medium, shall be made of that fact and of any 

maintenance work necessary to achieve the successful result. This record shall be 

kept at the location where the locomotive is maintained until a record of a 

subsequent successful test is filed. The download shall be taken from information 

stored in the certified crashworthy crash hardened event recorder memory module 

if the locomotive is so equipped. 
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Guidance

Section (a): The MU locomotives are only required to comply with Sections (b) and (c) if so 

equipped. 

Locomotives equipped with 26-L type brake equipment qualify for an industry-wide waiver 

(H80-7) that has been in effect since 1985, which extends the time requirement for §§ 

229.27(a)(2) and 229.29(a) to 1,104 days. In 2005, the industry was granted another waiver that 

extends the time requirement to 1,472 days for locomotives equipped with 26-L type brake 

equipment and a functioning air dyer. Under this waiver, the air dryer must be maintained and 

all air brake filtering devices must be cleaned or replaced annually. See waiver FRA-2005-

21325. 

Note: All other provisions of § 229.27 are performed on a 368-day cycle. Therefore, main 

reservoir filtering devices or dirt collectors in the supply line shall be cleaned, repaired, or 

replaced on an annual cycle. Form FRA F6180-49A should indicate the waiver under which the 

locomotive is operating. 

The following components should receive attention on the 1,104-day or the 1,472-day cycle: 

26-C Brake Valve 

SA-26 Ind. Brake Valve 

F-1 Selector Valve 

A-1 CCOP Valve 

BP Strainer 

Foot Valve 

Double Check Valves 

H Type Relayair Valves 

P-2-A Brake Application Valve 

Reducing Valves 

MU-2A Valves 

26-D & 26-F Control Valve 

J Type Relay Valve 

# 8 or KM Vent Valves 

MR Safety Valves 

MR Check Valves 

Magnet Valves 

The 30-CDW Console Mounted Brake Valve is considered to be the same as the 26-C and SA-26 

brake valve. 

Any other deviations in the brake valve, control valve, relay valve, or brake application valve 

exclude the entire equipment from the extension. For example, if there is a distributing valve in 

the system, the locomotive does not qualify for either the 1,104- or 1,472-day extension. RCL 

brake valves added to 26L type brake equipment are not part of the general industry-wide 

waivers and have to be inspected accordingly. 

Locomotives equipped with either the EPIC or CCB electronic brake system have been granted 

waivers that extend the time requirement to a 5-year cycle. However, these waivers are 

conditional and require that all of the filtering devices be cleaned, repaired, or replaced; and the 

brake pipe vent valve be inspected, cleaned, repaired, and tested on a 368-calendar-day interval. 

Recently, another test waiver was granted to the Association of American Railroads (AAR) to 

extend the time requirement beyond the 5-year period. Please be governed by the Form FRA 

F6180-49A - Blue Card on the locomotive. 
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Section (a)(4): Fragmentation of air brake clean, repair, and test (maintenance) is becoming 

more common due to electronic air brake waivers granted to several railroads under the umbrella 

of AAR waiver FRA-2005-21613. Specific conditions related to fragmenting may be listed in 

the waiver approval letter applicable to an individual railroad. Whether or not there is an 

applicable waiver, a railroad that implements a fragmented schedule of locomotive air brake 

maintenance, as permitted by 229.27(a)(4), is required to have an air record (an “air card” or 

other documentation) in the cab of the locomotive that lists the various air brake components and 

the date that each component went through its most recent clean, repair, and test cycle. The line 

on the Blue Card that is labeled “Airbrake 229.27" may be left blank or filled in with the word 

“Fragmented” or “Fragmented - See air card,” or it may be labeled as applicable to “Filters only” 

under Section 229.27(a)(1), if maintenance of the filters is recorded here and not on the air card. 

Entries on the “Air Brake 229.27" line for a locomotive that has a fragmented schedule of air 

brake maintenance are permissible, if the “Test date and Place” are provided for the oldest

component (among those listed in 229.27(a)(1) or (a)(2)) shown on the air card. 

Section (b): Displays that provide an indication of air pressure electronically shall be tested. 

Indicators used as load meters are required to be tested. Often there are questions pertaining to 

the requirement for testing load meters on locomotives equipped with AC traction motors, which 

use a computer screen to display loading information. Since an analog load meter indicating the 

current or amperage being applied to the traction motors is not included or required on the AC 

locomotive control stand, the regulation does not apply. The information provided to an 

engineer operating an AC locomotive is the electric power output, as indicated by tractive effort 

in pounds. In many cases, a bar graph displays the tractive effort as a percentage of the 

locomotive’s total output. 

The direct current traction motor analog load meter indicates short-time high amperage zones, 

which alert the engineer to possible overheating of the traction motor. The AC traction motor 

has no commutator or brushes, thus full current can be applied without damage because the 

computers automatically control loading at proper levels to prevent motor damage. (MP&E 98-

54)

§ 229.29 Biennial tests.

(a) Except for the valves and valve portions on non-MU locomotives that are cleaned, 

repaired, and tested as prescribed in § 229.27(a), all valves, valve portions, MU 

locomotive brake cylinders and electric-pneumatic master controllers in the air brake 

system (including related dirt collectors and filters) shall be cleaned, repaired, and tested 

at intervals that do not exceed 736 calendar days. The date and place of the cleaning, 

repairing, and testing shall be recorded on Form FRA F 6180-49A, and the person 

performing the work and that person’s supervisor shall sign the form. A record of the 

parts of the air brake system that are cleaned, repaired, and tested shall be kept in the 

carrier’s files or in the cab of the locomotive. 
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(b) At its option, a carrier may fragment the work required by this section. In that event, a 

separate air record shall be maintained under a transparent cover in the cab. The air 

record shall include the locomotive number, a list of the air brake components, and the 

date and place of the inspection and test of each component. The signature of the person 

performing the work and the signature of that person’s supervisor shall be included for 

each component. A duplicate record shall be maintained in the carrier’s files. 

Guidance

Locomotive air dryers (“air dryers”) are not specifically addressed by Federal safety laws (see 49 

CFR part 229 and 49 U.S.C. § 20107), nor has FRA determined that air dryers are an 

appurtenance to the locomotive for purposes of 49 CFR § 229.7. Because air dryers are not 

addressed by Federal safety laws, no violations should be taken for defective air dryers. 

In a number of the waivers granted by FRA’s Safety Board (“Safety Board”) to extend the 

intervals between brake maintenance (similar to the cleaning, repairing, and testing commonly 

referred to as COT&S) on both freight (49 CFR § 229.29, Biennial test) and passenger (49 CFR 

§ 238.309, Periodic brake equipment maintenance), the Safety Board required a functioning air 

dryer as a condition to the waiver. If a locomotive covered by a waiver that requires a 

functioning air dryer, is beyond the current brake maintenance interval in the regulation, and is 

found to have a defective air dryer, the locomotive would be noncompliant under 49 CFR §§ 

229.29 or 238.309 because of the overdue brake maintenance, and not for the defective air dryer. 

The waivers do not explain how FRA will determine whether an air dryer is defective. Violation 

reports must explain the basis for the inspector’s determination that the air dryer is defective. As 

a note, inspectors should not rely only on the air dryer’s color indicator to make the 

determination. 

Section (a): This section refers to all other valves in the air brake system. As noted in the 

guidance for § 229.27, a waiver was granted in 1985 that allows any locomotive with a 26-L type 

air brake system to go a total of 1,104 days between the required cleaning, repairing, and testing. 

Locomotives equipped with either the EPIC or CCB electronic brake system have been granted 

conditional waivers that extend the time requirement for cleaning, repairing, and testing valves 

and valve portions to a 5-year cycle.

When part 229 was promulgated, MU locomotives were subject to a 2-year inspection interval 

and this was not changed until the Passenger Equipment Safety Standards were written. It is still 

736 days, except as provided in § 238.309(b)(2) “Every 1,104 days if the MU locomotive is part 

of a fleet that is 100% equipped with air dryers and is equipped with PS-68, 26-C, 26-L, PS-90, 

CS-1, RT-2, RT-5A, GRB-1, CS-2, or 26-R brake systems.” 

Section (b): Handle similarly to fragmentation of brake maintenance under 229.27(a)(4) above, 

however in this case all components will be covered on the air card so the “Airbrake 229.29" line 

on the Blue Card should be left blank or labeled “Fragmented” or “Fragmented - See air card.” 

Entries on the Air Brake 229.29 line on a locomotive with fragmented air brakes are permissible, 

if the “Test date and Place” are provided for the oldest component shown on the air card. 

Recently, another test waiver was granted to the AAR to extend the time requirement beyond the 

5-year period. Please be governed by the Form FRA F6180-49A - Blue Card on the locomotive. 
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§ 229.31 Main reservoir tests. 

(a) Except as provided in paragraph (c) of this section, before it is put in service and at 

intervals that do not exceed 736 calendar days, each main reservoir other than an 

aluminum reservoir shall be subjected to a hydrostatic pressure of at least 25 percent 

more than the maximum working pressure fixed by the chief mechanical officer. The test 

date, place, and pressure shall be recorded on Form FRA F 6180-49A, and the person 

performing the test and that person’s supervisor shall sign the form. 

(b) Except as provided in paragraph (c) of this section, each main reservoir other than an 

aluminum reservoir shall be hammer tested over its entire surface while the reservoir is 

empty at intervals that do not exceed 736 calendar days. The test date and place shall be 

recorded on Form FRA F 6180-49A, and the person performing the test and that person’s 

supervisor shall sign the form. 

(c) Each welded main reservoir originally constructed to withstand at least five times the 

maximum working pressure fixed by the chief mechanical officer may be drilled over its 

entire surface with telltale holes that are three-sixteenths of an inch in diameter. The 

holes shall be spaced not more than 12 inches apart, measured both longitudinally and 

circumferentially, and drilled from the outer surface to an extreme depth by the formula 

displayed in the current 49 CFR part 229. One row of holes shall be drilled lengthwise of 

the reservoir on a line intersecting the drain opening. A reservoir so drilled does not have 

to meet the requirements of paragraphs (a) and (b) of this section, except the requirement 

for a hydrostatic test before it is placed in use. Whenever any such telltale hole shall have 

penetrated the interior of any reservoir, the reservoir shall be permanently withdrawn 

from service. A reservoir now in use may be drilled in lieu of the tests provided for by 

paragraphs (a) and (b) of this section, but it shall receive a hydrostatic test before it is 

returned to use. 

(d) Each aluminum main reservoir before being placed in use and at intervals that do not 

exceed 736 calendar days thereafter, shall be -- 

(1) Cleaned and given a thorough visual inspection of all internal and external 

surfaces for evidence of defects or deterioration; and 

(2) Subjected to a hydrostatic pressure at least twice the maximum working 

pressure fixed by the chief mechanical officer, but not less than 250 psi. The test 

date, place, and pressure shall be recorded on Form FRA F 6180-49A, and the 

person conducting the test and that person’s supervisor shall sign the form. 

Guidance 

Section (c): The word “drilled” is to be inserted in the hammer and hydro block on the FRA 

Form F6180.49A. The exterior of the drilled reservoirs are to be examined for their general 

condition. 
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§ 229.33 Out-of-use-credit. 

When a locomotive is out of use for 30 or more consecutive days or is out of use when it is due 

for any test or inspection required by § 229.23, 229.25, 229.27, 229.29, or 229.31, an “out-ofuse” notation showing the number of out-of-use days shall be made on an inspection line on 

Form FRA F6180-49A. A supervisory employee of the carrier who is responsible for the 

locomotive shall attest to the notation. If the locomotive is out of use for one or more periods of 

at least 30 consecutive days each, the interval prescribed for any test or inspection under this part 

may be extended by the number of days in each period the locomotive is out of use since the last 

test or inspection in question. A movement made in accordance with § 229.9 is not a use for 

purposes of determining the period of the out-of-use credit. 

Guidance

The out-of-use credit inserted on an inspection line of the FRA Form F6180.49A accounts for the 

continuous record of a locomotive’s use for a calendar year. These random days cannot be 

accumulated nor used to extend the intervals prescribed for any test or inspection under this part, 

unless the time period is for 30 or more consecutive days. The creditable out-of-use time of 30 

or more days, which is used to extend the test or inspection intervals, must be recorded in Block 

Number 11 on the FRA Form F6180.49A when a new form is created. Once the credit is used, it 

should be deleted from the form. 

If a railroad leases a locomotive to a private industry and it is used entirely within the confines of 

a plant that is not a part of the general railroad system, the locomotive cannot be credited as outof-use time because the locomotive is being used. When the railroad has a leased locomotive 

returned, the railroad must bring it into compliance with all of part 229 before it can be used in 

general railroad service. 

§ 229.41 Protection against personal injury. 

Fan openings, exposed gears and pinions, exposed moving parts of mechanisms, pipes carrying 

hot gases and high-voltage equipment, switches, circuit breakers, contactors, relays, grid 

resistors, and fuses shall be in non-hazardous locations or equipped with guards to prevent 

personal injury. 

Guidance

 

The requirements of this section are designed to protect against safety hazards that could cause 

personal injuries. 

§ 229.43 Exhaust and battery gases. 

(a) Products of combustion shall be released entirely outside the cab and other 

compartments. Exhaust stacks shall be of sufficient height or other means provided to 

prevent entry of products of combustion into the cab or other compartments under usual 

operating conditions. 
Motive Power and Equipment Compliance Manual 

8 - 33 

(b) Battery containers shall be vented and batteries kept from gassing excessively. 

Guidance

Section (a): The exhaust system of a locomotive should be inspected closely while the diesel 

engine is running for cracks in the manifolds and expansion bellows, broken or blown out 

manifold gaskets, and other signs of exhaust gas discharge into the engine compartment, as 

evidenced by heavy accumulations of soot and residue. The lay shaft should not be operated by 

inspectors to accelerate the diesel engine to check for exhaust leaks. If there is evidence of an 

exhaust leak, the railroad should be requested to operate the lay shaft or rev the engine to locate 

the leak. Instances have been mentioned by some railroads in which inspectors have reported 

exhaust leaks and railroad inspectors could not find them. Since the advent of the EMD GP-30 

and its successors, and the GE U-25-B and its successors, the locomotive diesel engine 

compartments are pressurized to the extent that any residual fumes in the car body will be 

scavenged to the atmosphere around the exhaust stack opening in the roof. 

§ 229.45 General Conditions. 

All systems and components on a locomotive shall be free of conditions that endanger the safety 

of the crew, locomotive or train. These conditions include: insecure attachment of components, 

including third rail shoes or beams, traction motors and motor gear cases, and fuel tanks; fuel, 

oil, water, steam, and other leaks and accumulations of oil on electrical equipment that create a 

personal injury hazard; improper functioning of components, including slack adjusters, 

pantograph operating cylinders, circuit breakers, contactors, relays, switches, and fuses; and 

cracks, breaks, excessive wear and other structural infirmities of components, including quill 

drives, axles, gears, pinions, pantograph shoes and horns, third rail beams, traction motor gear 

cases, and fuel tanks. 

Guidance

This regulation is basically a compendium of many regulations found in the former part 230. 

When this regulation was written, the railroads were concerned that the provisions of this 

regulation created a degree of discretion in interpretation and application by the MP&E 

inspectors. FRA’s position is that its inspectors have always interpreted the regulations in part 

230 in a reasonable manner. FRA also believes that, “conditions that endanger the safety of the 

crew, locomotive, or train” provide the proper and lawful limit to the application of this section. 

Conditions described as fuel, oil, water, steam, and other leaks must be qualified by stating that 

they constitute a personal injury hazard. Insecure attachments of those items such as third rail 

shoes or beams, traction motors and motor gear cases, and fuel tanks should have some 

relevancy to safety, or have deteriorated to the point that it is immediately unsafe and could 

cause an accident. A locomotive should not be cited for conditions described above if they do 

not constitute a hazard of any type, but are merely technical in nature. However, the railroad 

should be required to correct the condition and bring the locomotive into compliance. Any 

safety appliances not covered in part 231, such as steps and handholds that aid in sanding 
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locomotives, safety railings, and ladder treads affording access to the roof of the locomotive are 

covered by this section. Similarly, if the sander hose or pipe has a hole in it that discharges sand 

at eye level, the inspector must establish the personal injury hazard under 229.45. The inspector 

must explain how the blowing would cause the injury (e.g. sand blowing at eye level on 

locomotive walkway, etc.). inspectors should use this code if or when they find a handle missing 

or the locking feature defective on locomotive air brake MU end-cocks, since these conditions 

may affect the operation of the locomotive’s brakes. 

When a violation is submitted for any of the conditions described in this section, the personal 

injury hazard should be described to include a full explanation of the condition and how it 

creates a personal hazard. 

§ 229.46 Brakes: General. 

The carrier shall know before each trip that the locomotive brakes and devices for regulating all 

pressures, including but not limited to the automatic and independent brake valves, operate as 

intended and that the water and oil have been drained from the air brake system. 

Guidance

The inspector should observe railroad personnel performing the required air brake test on a 

locomotive(s). 

Inspectors should check that someone, before the start of the trip, drained the oil and water from 

the air brake system. FRA considers the trip in “yard operations” to be the start of the shift. The 

mere presence of water or oil in the brake system in and of itself does not establish a violation 

under this section. Nor does the fact that there is oil or water in the system following a daily 

inspection establish a violation. In order to establish a violation, FRA must prove that the water 

and oil was not drained from the system before the trip (for which the violation is being sought) 

began. Thus, if oil or water is present, the inspector should discuss why the presence of such 

could not have occurred while the locomotive was en route on its trip (length of trip vs. amount 

of oil and water). The mere fact that a daily inspection was performed does not establish a 

violation under this section. FRA must establish that the oil or water was not drained prior to the 

commencement of the involved trip. 

Most of the road locomotives are equipped with some type of automatic main air reservoir drain 

valve to drain the water and oil from the air brake system. Usually when the automatic drain 

valve is cut out or inoperative, water and oil will accumulate in the reservoir. In this case, 

inspectors should take exception to an inoperative (defective or nullified) automatic drain valve. 

If the automatic drain valve is found to be inoperative or nullified, but no water or oil is present 

in the reservoir, a noncomplying condition does not exist under this section. Since it is an 

appurtenance to the locomotive, § 229.7 could be used for enforcement. 

§ 229.47 Emergency brake valve. 
Motive Power and Equipment Compliance Manual 

8 - 35 

(a) Except for locomotives with cabs designed for occupancy by only one person, each 

road locomotive shall be equipped with a brake pipe valve that is accessible to a member 

of the crew, other than the engineer, from that crew member’s position in the cab. On car 

body type locomotives, a brake pipe valve shall be attached to the wall adjacent to each 

end exit door. The words “Emergency Brake Valve” shall be legibly stenciled or marked 

near each brake pipe valve or shall be shown on an adjacent badge plate. 

(b) MU and control cab locomotives operated in road service shall be equipped with an 

emergency brake valve that is accessible to another crew member in the passenger 

compartment or vestibule. The words “Emergency Brake Valve” shall be legibly 

stenciled or marked near each valve or shall be shown on an adjacent badge plate. 

Guidance

Section (a): The emergency brake valve may be found in various locations on different 

locomotives. There is no precise location except that it must be readily accessible to someone 

other than the engineer, and on locomotives with enclosed walkways there must be an additional 

valve adjacent to the rear exit doors. Although the requirement does not address location of the 

valve within the cab, the required stenciling near each valve must be visible. If a valve is located 

behind a cab seat where a crew member must fold the seat down in order to activate it, the 

required stenciling must not be obstructed. The required stenciling must be visible to identify the 

valve’s location. 

Section (b): The emergency brake valve must be located in the passenger compartment and must 

be connected to the brake pipe. 

Good enforcement discretion should be used if the “Emergency Brake Valve” designation is 

found not intact. The condition should be brought to the railroad’s attention for correction. The 

inspector should periodically have the railroad test the emergency valve on the locomotive on a 

random basis to insure proper operation. 

§ 229.49 Main reservoir system. 

(a) (1) The main reservoir system of each locomotive shall be equipped with at least 

one safety valve that shall prevent an accumulation of pressure of more than 15 

pounds per square inch above the maximum working air pressure fixed by the 

chief mechanical officer of the carrier operating the locomotive. 

(2) Except for non-equipped MU locomotives built prior to January 1, 1981, each 

locomotive that has a pneumatically actuated system of power controls shall be 

equipped with a separate reservoir of air under pressure to be used for operating 

those power controls. The reservoir shall be provided with means to automatically 

prevent the loss of pressure in the event of a failure of main air pressure, have 

storage capacity for not less than three complete operating cycles of control 

equipment and be located where it is not exposed to damage. 
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8 - 36 

(b) A governor shall be provided that stops and starts or unloads and loads the air 

compressor within 5 pounds per square inch above or below the maximum working air 

pressure fixed by the carrier. 

(c) Each compressor governor used in connection with the automatic air brake system 

shall be adjusted so that the compressor will start when the main reservoir pressure is not 

less than 15 pounds per square inch above the maximum brake pipe pressure fixed by the 

carrier and will not stop the compressor until the reservoir pressure has increased at least 

10 pounds. 

Guidance

The inspector should periodically have the railroad demonstrate the functioning and setting of 

the safety valve and compressor governor at locations where periodic inspections are performed. 

Union Pacific Railroad (UP) requested and was granted a conditional waiver to permit UP 

locomotive main reservoir system safety valve to accumulate up to 25 psi above the maximum 

working air pressure fixed by the chief mechanical officer, the maximum allowed by regulation 

is 15 psi. This waiver was assigned Docket Number FRA-2005-21179. A copy of the decision 

letter is available in the MP&E waiver section of this Compliance Manual. 

§ 229.51 Aluminum main reservoirs. 

(a) Aluminum main reservoirs used on locomotives shall be designed and fabricated as 

follows: 

(1) The heads and shell shall be made of Aluminum Association Alloy No. 5083- 

0, produced in accordance with American Society of Mechanical Engineers 

(ASME) Specification SB-209, as defined in the “ASME Boiler and Pressure 

Vessel Code” (1971 edition), section II, Part B, page 123, with a minimum tensile 

strength of 40,000 psi (40 ksi). 

(2) Each aluminum main reservoir shall be designed and fabricated in accordance 

with the “ASME Boiler and Pressure Vessel Code,” section VIII, Division I (1971 

edition), except as otherwise provided in this part. 

(3) An aluminum main reservoir shall be constructed to withstand at least five (5) 

times its maximum working pressure or 800 psi., whichever is greater. 

(4) Each aluminum main reservoir shall have at least two inspection openings to 

permit complete circumferential visual observation of the interior surface. On 

reservoirs less than 18 inches in diameter, the size of each inspection opening 

shall be at least that of 11⁄2-inch threaded iron pipe, and on reservoirs 18 or more 

inches in diameter, the size of each opening shall be at least that of 2-inch 

threaded iron pipe. 
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(b) The following publications, which contain the industry standards incorporated by 

reference in paragraph (a) of this section, may be obtained from the publishers and are 

also on file in the Office of Railroad Safety of the Federal Railroad Administration, 

Washington, DC 20590. Sections II and VIII of the “ASME Boiler and Pressure Vessel 

Code” (1971 edition) are published by the American Society of Mechanical Engineers, 

United Engineering Center, 345 East 47th Street, New York, NY 10017. 

Guidance

Currently, aluminum main air reservoirs are not in use. This section is included in the regulation 

to provide design guidance. If an inspector finds an aluminum air reservoir, the regional office 

should be immediately notified and the information forwarded to the MP&E Staff Director. 

§ 229.53 Brake gauges. 

All mechanical gauges and all devices providing indication of air pressure electronically that are 

used by the engineer to aid in the control or braking of the train or locomotive shall be located so 

that they may be conveniently read from the engineer’s usual position during operation of the 

locomotive. A gauge or device shall not be more than five percent or three pounds per square 

inch in error, whichever is less. 

Guidance

The regulation pertains only to gauges and displays used by the engineer for controlling or 

braking a train or locomotive pneumatically. All other air gauges located at other locations on a 

locomotive are not included. Gauges and preset pressure devices on the belt packs used in 

remote control locomotive operations are subject to this section. 

§ 229.55 Piston Travel. 

(a) Brake cylinder piston travel shall be sufficient to provide brake shoe clearance when 

the brakes are released. 

(b) When the brakes are applied on a standing locomotive, the brake cylinder piston 

travel may not exceed 11⁄2 inches less than the total possible piston travel. The total 

possible piston travel for each locomotive shall be entered on Form FRA F 6180-49A. 

(c) The minimum brake cylinder pressure shall be 30 pounds per square inch. 

Guidance

Section (b): The requirements are that the piston’s travel not exceed 11⁄2 inches less than the total 

possible piston travel. This measurement can be found on the locomotive’s blue card, FRA 

Form F6180-49A. Inspectors should periodically check the 49A card for accurate 

measurements. On a typical locomotive in service today, the total piston travel for truckmounted brake cylinders is 8-inches; therefore, the allowable piston travel shall not exceed 61⁄2 
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inches. Excessive piston travel of a minor nature on only one cylinder should not necessarily 

result in a violation, but the railroad should be requested to repair it. When measuring piston 

travel on locomotives, the measurement is from the opening of the cylinder to the collar. It is not 

the grease ring, as is the practice when measuring piston travel on freight cars. 

Section (c) is in regards to the minimum locomotive brake cylinder pressure required by the 

Federal regulations. These regulations were written when cast iron brake shoes were the 

standard and the brake cylinder relay air valve delivered 100 percent of the control pressure to 

the brake cylinders. With the advent of the high friction composition brake shoe, various relay 

valves have been used depending on whether the rigging was designed for cast iron or 

composition shoes. To best match the stop distance of cast iron, a two-step relay valve is used 

for composition shoes. One level is used for the automatic brake where speeds are generally 

above “switching” speeds, and a higher level for the independent brake that is normally used in 

switching. By tailoring the relay valve to the locomotive, a standard independent brake valve 

setting can be used universally on a railroad. This setting is usually 45 psi. The resulting brake 

cylinder pressure may vary from 27 psi (with a 60 percent relay) to 72 psi (with a 160 percent 

relay). The 60 percent relay valves (J-46 or J-64) are normally found on older locomotives that 

were converted from cast iron shoes with clasp rigging to composition shoes with clasp rigging. 

Therefore, FRA considers such locomotives to be in compliance with the regulations. (MP&E 

98-41) 

§ 229.57 Foundation Brake Gear. 

A lever, rod, brake beam, hanger, or pin may not be worn through more than 30 percent of its 

cross-sectional area, cracked, broken, or missing. All pins shall be secured in place with cotters, 

split keys, or nuts. Brake shoes shall be fastened with a brake shoe key and aligned in relation to 

the wheel to prevent localized thermal stress in the edge of the rim or the flange. 

 

Guidance 

When out-of-line (overriding) brake shoes are discovered, the inspector should try to determine 

the root cause of the defect (e.g. bushings, hangers, pins, etc.) Also, the wheel should be 

examined for thermal stress at the edge of the wheel, as evidenced by small thermal cracks, metal 

flow, or discoloration. 

§ 229.59 Leakage. 

(a) Leakage from the main air reservoir and related piping may not exceed an average of 

3 pounds per square inch per minute for 3 minutes after the pressure has been reduced to 

60 percent of the maximum pressure. 

(b) Brake pipe leakage may not exceed five (5) pounds per square inch per minute. 

(c) With a full service application at maximum brake pipe pressure and with 

communication to the brake cylinders closed, the brakes shall remain applied at least five 

(5) minutes. 
Motive Power and Equipment Compliance Manual 

8 - 39 

(d) Leakage from control air reservoir, related piping, and pneumatically operated 

controls may not exceed an average of three (3) pounds per square inch per minute for 

three (3) minutes. 

Guidance

Section (a): An air leak from the main air reservoir system cannot be considered noncomplying 

unless it is in excess of 3 pounds as described in this section. If the inspector believes that the 

leak is excessive, he/she should have the railroad perform the required test procedure. 

Section (b): After an automatic brake pipe reduction of at least 20 psi (not to exceed full service) 

is made, wait 45–60 seconds, and if the locomotive is equipped with the means for maintaining 

brake pipe pressure, this feature must be cut out. Next, observe if the brake pipe leakage exceeds 

5 psi per minute. 

Section (c): Leakage of air observed at a brake cylinder in itself may not be a noncomplying 

condition. A noncomplying condition would be present if the brakes did not remain applied for 

5 minutes as a result of the leak. This can only be determined after communication from the 

automatic brake valve is cut off at the completion of a full service application. The railroad 

should perform the required test for the MP&E inspector. 

Section (d): This system will only be found on locomotives which use air-operated electric 

power contactors and/or an air-operated throttle. 

§ 229.61 Draft system. 

(a) A coupler may not have any of the following conditions: 

(1) A distance between the guard arm and the knuckle nose of more than 51⁄8 

inches on standard type couplers (MCB contour 1904) or more than 5- 5/16 

inches on D&E couplers. 

(2) A crack or break in the side wall or pin bearing bosses outside of the shaded 

areas shown in Figure 1 or in the pulling face of the knuckle. 

(3) A coupler assembly without anti-creep protection. 

(4) Free slack in the coupler or drawbar not absorbed by friction devices or draft 

gears that exceeds one-half inches. 

(5) A broken or cracked coupler carrier. 

(6) A broken or cracked yoke. 

(7) A broken draft gear. 
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(b) A device shall be provided under the lower end of all drawbar pins and articulated 

connection pins to prevent the pin from falling out of place in case of breakage. 

Guidance

Coupler heights and safety appliances should be examined for compliance with the Safety 

Appliance Standards, and all deficiencies should be reported under part 231. The coupler heights 

must be measured on level, tangent track. The standard height for locomotive coupler is 

identical to freight and passenger car: the standard gauge railroad center of the knuckle shall be 

a maximum of 341⁄2 inches, and a minimum of 311⁄2 inches, above the top of the rail. 

Section (a)(2): The definition of a crack or break must be applied judiciously used when 

examining a coupler for such noncomplying conditions. If the condition observed is a shrinkage 

crack or a hot tear (a phenomenon that occurs during the casting process), it does not 

significantly diminish the strength of the coupler, and thus is not considered to be a crack or 

noncomplying condition. For additional information on coupler cracks, see the guidance related 

to draft systems for freight cars contained in Chapter 4, Section 215.123. 

 

Section (a)(3): Most freight-hauling locomotives have a top-operated lock lifter. As long as 

there is clearance in the operating loop when the knuckle is closed, the anti-creep should be 

functioning. 

Section (a)(4): This pertains to all types of locomotives regardless of the service to which they 

are put. The lost motion or draft system free slack is that which is not absorbed by the draft gear 

or similar equipment. The free slack can be determined by manually placing the coupler in draft 

and buff position, scribing a mark at each position on the side of the coupler horn, and then 

measuring the distance between the two marks. 

§ 229.63 Lateral motion. 

(a) Except as provided in paragraph (b), the total uncontrolled lateral motion between the 

hubs of the wheels and boxes, between boxes and pedestals or both, on any pair of wheels 

may not exceed one (1) inch on non-powered axles and friction bearing powered axles, or 

3⁄4 inch on all other powered axles. 

(b) The total uncontrolled lateral motion may not exceed 1 1⁄4 inches on the center axle of 

three-axle trucks. 

Guidance

The “total uncontrolled lateral motion” referred to in this section means the lateral motion 

provided for in the design of the parts, plus any additional lateral motion due to wear. The 

inspector may have to measure several points of an axle assembly to calculate the total clearance. 

§ 229.64 Plain bearings. 
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A plain bearing box shall contain visible free oil and may not be cracked to the extent that it will 

leak oil. 

 

Guidance

Only plain bearing boxes are referenced in this section, and then only in a very restrictive 

manner. Any mechanical defect in the friction bearings, as well as any defects found in a roller 

bearing assembly, shall be reported under Section 229.45, General Conditions. Obvious 

hazardous conditions found when inspecting either friction or roller bearings not specifically 

covered by these regulations may be handled by the use of a Special Notice for Repairs, FRA 

Form F6180.8. 

§ 229.65 Spring rigging. 

(a) Protective construction or safety hangers shall be provided to prevent spring planks, 

spring seats or bolsters from dropping to track structure in event of a hanger or spring 

failure. 

(b) An elliptical spring may not have its top (long) leaf broken or any other three leaves 

broken, except when that spring is part of a nest of three or more springs and none of the 

other springs in the nest has its top leaf or any other three leaves broken. An outer coil 

spring or saddle may not be broken. An equalizer, hanger, bolt, gib, or pin may not be 

cracked or broken. A coil spring may not be fully compressed when the locomotive is at 

rest. 

(c) A shock absorber may not be broken or leaking clearly formed droplets of oil or other 

fluid. 

Guidance

Section (b): This section is restricted in application. Many of the locomotives presently in 

service using elliptical springs have more than three leaf springs in a nest. A locomotive may 

have a long leaf broken and up to two other smaller leaves broken, or up to five smaller leaves 

broken, provided that no other long leaves are broken. The context of the aforementioned 

guidance applies to elliptical springs that are only part of a nest of three or more. At no time 

may a locomotive have two (2) long leaves broken. 

Also, many locomotives are equipped with rubber/steel laminated pads instead of leaf springs, 

and where such pads are found to be defective or deteriorated and they create an unsafe 

condition, they should be reported under Section 229.45. 

Only the outer coil spring is addressed in this section. All coil springs in a truck assembly are to 

be inspected and considered, such as those that are used to support the span bolster on the EMD 

SD series of locomotives, and must be in compliance with this section. A spring plank resting on 

or in contact with the safety hanger should be reported. 
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Section (c): “Clearly formed droplets” means a fresh accumulation of oil (not dirty or dried) 

that continually and/or slowly forms into beads. If there is evidence of the unit being ineffective, 

it is considered defective. This applies to shock absorbers and yaw dampers. 

§ 229.67 Trucks. 

§ 229.69 Side Bearings. 

(a) Friction side bearings with springs designed to carry weight may not have more than 

25% of the springs in any one nest broken. 

(b) Friction side bearings may not be run in contact unless designed to carry weight. 

Maximum clearance of side bearings may not exceed one-fourth inch on each side or a 

total of one-half inch on both sides, except where more than two side bearings are used 

under the same rigid superstructure. The clearance on one pair of side bearings under the 

same rigid superstructure shall not exceed one-fourth inch on each side or a total of onehalf inch on both sides; the other side bearings under the same rigid superstructure may 

have one-half inch clearance on each side or a total of 1 inch on both sides. These 

clearances apply where the spread of the side bearings is 50 inches or less; where the 

spread is greater, the side bearing clearance may only be increased proportionately. 

Guidance 

Section (b): Side bearings may not run in contact unless they are designed to carry weight. To 

determine that there is no clearance between a pair of side bearings that appear to be in contact at 

both sides, the inspector must use a thin feeler gauge to make the determination as to whether 

clearance exists. 

There are two measurements allowed on a locomotive which has two (2) trucks under the same 

structure. A total not to exceed 1⁄2 inch is allowed at the side bearings of one truck and under the 

same superstructure, a total not to exceed 1 inch is allowed on trucks with more than one pair of 

side bearings per truck. The superstructure is only that part over the trucks. Inspectors must be 

cognizant of truck configurations that allow for more than one pair of side bearings on one truck. 

No exception should be taken if all of the side bearing clearance is to one side and there is no 

apparent problem with the locomotive. All side bearing measurements must be taken on 

tangent, level track.

§ 229.73 Wheel sets. 

(a) The variation in the circumference of wheels on the same axle may not exceed 1/4 

inch (two tape sizes) when applied or turned. 

(b) The maximum variation in the diameter between any two wheel sets in a threepowered-axle truck may not exceed 3⁄4 inch, except that when shims are used at the 

journal box springs to compensate for wheel diameter variation, the maximum variation 
Motive Power and Equipment Compliance Manual 

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may not exceed 11⁄4 inch. The maximum variation in the diameter between any two wheel 

sets on different trucks on a locomotive that has three-powered-axle trucks may not 

exceed 11⁄4 inch. The diameter of a wheel set is the average diameter of the two wheels on 

an axle. 

(c) On standard gauge locomotives, the distance between the inside gauge of the flanges 

on non-wide flange wheels may not be less than 53 inches or more than 531⁄2 inches. The 

distance between the inside gauge of the flanges on wide flange wheels may not be less 

than 53 inches or more than 531⁄4 inches. 

(d) The distance back to back of flanges of wheels mounted on the same axle shall not 

vary more than 1⁄4 inch. 

Guidance

Section (b): This section deals with the problem of mismatched wheels that are identified as (1) 

wheel slip control, (2) traction motor current unbalance, and (3) axle load variations. 

(1) The wheel slip control system brings into play either manual sanding by the 

engineer or automatic sanding triggered as the response to arrest the wheel slip. 

In either case, sanding may substantially increase the ratio of lateral to vertical 

forces creating a derailment possibility. 

(2) Traction motor current unbalance results in different current levels between 

the motors in the truck that affects the traction motor operating temperature, and 

the distribution of tractive effort. 

(3) The axle load variation caused by different wheel sizes affects the adhesion 

level demand at various axle locations since some axles are called upon to accept 

more or less of the locomotive’s weight then they would with equal wheel sizes. 

This affects the tracking characteristics of the locomotive. A lightly loaded 

leading axle of a truck would have a greater tendency to climb the rail in a curve 

or at track irregularities, while a heavily loaded axle has the same effect on the 

track structure as a heavier locomotive. 

Inspectors are advised that this regulation applies only to three powered axle trucks. Inspectors 

should employ the witness groove method to determine the wheel diameter. To properly 

measure the diameter of a locomotive wheel, measure the distance from the top of the reference 

(witness) groove to the outer edge of the rim, multiply by two, and add 36 inches. A standard 

steel wheel gage (finger gage) would normally be used for this measurement. Gauge W319 can 

also be used to determine a wheel’s diameter, especially if 44-inch wheels are involved. 

§ 229.75 Wheels and tire defects. 

Wheels and tires may not have any of the following conditions: 
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(a) A single flat spot that is 21⁄2 inches or more in length, or two (2) adjoining spots that 

are each two (2) or more inches in length. 

(b) A gouge or chip in the flange that is more than 11⁄2 inches in length and 1⁄2 inch in 

width. 

(c) A broken rim, if the tread, measured from the flange at a point five-eighths inch above 

the tread, is less than 33⁄4 inches in width. 

(d) A shelled-out spot 21⁄2 inches or more in length, or two adjoining spots that are each 

two or more inches in length. 

(e) A seam running lengthwise that is within 33⁄4 inches of the flange. 

(f) A flange worn to a 7⁄8 inch thickness or less, gauged at a point 3/8 inch above the tread. 

(g) A tread worn hollow 5/16 inch or more on a locomotive in road service or 3/8 inch or 

more on a locomotive in switching service. 

(h) A flange height of 11⁄2 inches or more measured from tread to the top of the flange. 

(i) Tires less than 11⁄2 inches thick. 

(j) Rims less than one (1) inch thick on a locomotive in road service or less than 3⁄4 inch 

on a locomotive in yard service. 

(k) A crack or break in the flange, tread, rim, plate, or hub. 

(l) A loose wheel or tire. 

(m) Fusion welding may not be used on tires or steel wheels of locomotives, except for 

the repair of flat spots and worn flanges on locomotives used exclusively in yard service. 

A wheel that has been welded is a welded wheel for the life of the wheel. 

Guidance 

Great care should be exercised when measuring wheels for flat spots and high flanges. The 

inspector should use appropriate wheel gages and not include a measurement along with a 

noncomplying condition, unless the wheel defect in question is so severe that an additional 

monetary penalty can be established, as reflected in the penalty schedule. Additional guidance 

on how gages are used to measure wheels can be found in the guidance written for § 215.103. 

Section (k): A crack in the wheel will require some judgment on the part of the inspectors, 

especially those who regularly inspect MU locomotive equipment or locomotives used in 

commuter service. Those cracks that are found in discolored wheels that extend from the tread 

outward over the edge of the rim or into the flange should be considered as dangerous to the 
Motive Power and Equipment Compliance Manual 

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safety of the wheel and handled for correction with the railroad. If any crack appears to be 

opened, it should be reported because the wheel has gone into a state of tension, and any further 

thermal abuse may result in a broken wheel. These cracks are often referred to as thermal 

cracks, resulting from high speed, short distances, and the heavy braking required in commuter 

service. The inspector should be aware of such conditions and bring the issue to the specialist’s 

attention for evaluation and monitor the situation as required. 

Section (m): At the option of the railroad, welding of the wheels is permitted to make 

emergency repairs in order to move a road locomotive from an accident site or a location where a 

defective wheel cannot be replaced. However, any subsequent move can then only be made as 

required by Section 229.9 (i.e., the locomotive cannot be used in service and can only be moved 

lite or dead-in-tow). It is also permissible to weld wheels on locomotives used only in yard 

service. Yard is defined by “yard limits,” which are designated by the railroad and are usually 

found in the current timetable or established by posted signs. Locomotives with welded wheels 

can only operate on tracks within the designated limits of a yard, and whose movements are 

governed by Rule 93, of the AAR’s Standard Operating Rules. The minimum requirements of 

Rule 93 are defined in § 218.35. 

§ 229.77 Current collectors. 

(a) Pantographs shall be so arranged that they can be operated from the engineer’s normal 

position in the cab. Pantographs that automatically rise when released shall have an 

automatic locking device to secure them in the down position. 

(b) Each pantograph operating on an overhead trolley wire shall have a device for locking 

and grounding it in the lowest position that can be applied and released only from a 

position where the operator has a clear view of the pantograph and roof without mounting 

the roof. 

Guidance

The pantograph control switches or buttons are usually located on or near the engineer’s control 

panel, and should be operated by railroad personnel only. Inspectors should be alert when 

inspecting locomotives and MU locomotives in electrified territory. They should consider 

the catenary system and the current-carrying parts of the third-rail system to be energized and 

dangerous at all times. Inspectors should not get on the roof of any equipment when it is under 

the catenary system. Extreme care should be exercised with the use and handling of metal 

gauges and tools around electrical equipment and especially third-rail equipment. 

§ 229.79 Third rail shoes. 

When locomotives are equipped with both third rail and overhead collectors, third-rail shoes 

shall be de-energized while in yards and at stations when current collection is exclusively from 

the overhead conductor. 

Guidance
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8 - 46 

Inspectors should be aware that considerable force is exerted on third-rail shoe beams when in 

operation. Therefore, these beams must be properly secured on brackets, and not split and 

cracked. 

§ 229.85 Doors and cover plates marked “Danger.” 

All doors and cover plates guarding high voltage equipment shall be marked “Danger--High 

Voltage” or with the word “Danger” and the normal voltage carried by the parts so protected. 

Guidance

This item should only be reported as a defect if there are no markings to indicate an obvious area 

of high voltage. If the car body doors into the main generator or alternator generator 

compartment are marked “Danger-High Voltage” or “Danger,” but the generator itself does not 

have every cover so marked, especially if the covers are bolted in place, it should not be reported 

as a defect. Some logic has to be used by the inspector to determine if there is any imminent 

danger versus a technical defect in the absence of a cover not being marked. 

§ 229.89 Jumpers; cable connections. 

(a) Jumpers and cable connections between locomotives shall be so located and guarded 

to provide sufficient vertical clearance. They may not hang with one end free. 

(b) Cable and jumper connections between locomotive may not have any of the following 

conditions: 

(1) Broken or badly chafed insulation. 

 (2) Broken plugs, receptacles or terminals. 

(3) Broken or protruding strands of wire. 

Guidance 

Section (a): Jumper cables with one end hanging loose should not be taken as a violation when 

the locomotive is found standing unattended and the locomotive is not in use or assigned for 

service. Conversely, if locomotives are observed in use with one end of the jumper cable 

hanging free, appropriate enforcement action should be taken. This applies to a locomotive 

standing in a yard or within the confines of a locomotive servicing area. 

Inspectors should periodically lift the jumper receptacle lid to ensure that all terminal pins are in 

suitable condition for service. In addition, the jumper housing should be inspected to ensure that 

it seals properly and is free of cracks. 

§ 229.91 Motors and generators. 
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A motor or a generator may not have any of the following conditions: 

(a) Be shorted or grounded. 

(b) Throw solder excessively. 

(c) Show evidence of coming apart. 

(d) Have an overheated support bearing. 

(e) Have an excessive accumulation of oil. 

Guidance

One of the defects most often reported is accumulation of oil. The key word in the regulation is 

excessive. If the accumulation over the exterior of the motor or generator is not excessive, it 

should not be reported. Also, if it is an old accumulation as evidenced by debris and dirt, and no 

fresh oil is found, it should not be reported as a defect. 

§ 229.93 Safety cut-off device. 

The fuel line shall have a safety cut-off device that – 

(a) Is located adjacent to the fuel supply tank or in another safe location; 

(b) Closes automatically when tripped and can be reset without hazard; and 

(c) Can be hand operated from clearly marked locations, one inside the cab and one on 

each exterior side of the locomotive. 

Guidance

Since the introduction of the EMD GP-30 series locomotives in the 1950’s and the GE U-25 

series, the fuel safety cut-off devices have been incorporated in the emergency shut down 

switches. The earlier fuel safety cut-off devices consisted of a mechanical valve manually 

operated through a cable system from three locations. Resetting this valve is also manual. 

Safety shut-off devices of this type must be operable from three locations, one in the cab and one 

on each exterior side of the locomotive. The MP&E inspector is not to operate the safety cut-off 

device. The inspector should request that the railroad demonstrate the function on random 

inspections and whenever there is reason to believe the device is inoperable. If the required 

marking is missing or incomplete, a violation should not be filed, but it should be brought to the 

attention of the railroad for correction. As a result of an accident involving a runaway UP freight 

train that derailed at Hayden, California, FRA published a Notice of Safety Bulletin in the 

Federal Register on January 30, 1997. The notice requires all railroads to inspect locomotives to 

determine if the emergency MU fuel cut-off switch is located in such a position that it can be 
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inadvertently activated by the engineer. Inadvertent actuation of a switch located at knee level to 

the engineer is suspected as the cause of the Hayden, California, accident. 

During normal inspections, FRA inspectors should carefully examine the locomotive fuel cut-off 

switch for vulnerability to inadvertent actuation. When a locomotive is found to have such 

vulnerability, the inspector should work with the railroads to comply with the Notice of Safety 

Bulletin as quickly as possible. Any disagreements arising over whether a switch is vulnerable, 

that cannot be resolved at the regional level, should be referred to the MP&E Staff Director. 

(MP&E 98-60)

 

§ 229.95 Venting. 

§ 229.97 Grounding fuel tanks. 

Fuel tanks and related piping shall be electrically grounded. 

Guidance

There is no requirement for any type of fuel level gauge at the fuel oil reservoirs. Generally, all 

locomotives have fuel sight glasses of some type, but they are for the railroad’s convenience, as 

is the automatic fuel shut-off equipment that is used when fueling locomotives. 

§ 229.99 Safety hangers. 

Drive shafts shall have safety hangers. 

Guidance

The drive shaft hangers described in this section deal with a shaft that, if disconnected, could fall 

to the track structure and cause a derailment. These types of drive shafts are found on 

locomotives where the motive power uses a mechanical drive system to power the drive axles 

(e.g. Budd Company RDCs and the French Turbo trains). 

§ 229.101 Engines. 

(a) The temperature and pressure alarms, controls and related switches of internal 

combustion engines shall function properly. 

(b) Whenever an engine has been shut down due to mechanical or other problems, a 

distinctive warning notice giving reason for the shut-down shall be conspicuously 

attached near the engine starting control until repairs have been made. 

(c) Wheel slip/slide protection shall be provided on a locomotive with an engine 

displaying a warning notice whenever required by § 229.115(b). 

Guidance
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Section (a): The inspector should be alert to safety switches being nullified when inspecting the 

diesel engine on locomotives. Where actual tampering of the engine protective devices is found, 

violations should be considered. 

§ 229.103 Safe working pressure; factor of safety. 

The safe working pressure for each steam generator shall be fixed by the chief mechanical 

officer of the carrier. The minimum factor of safety shall be four. The fixed safe working 

pressure shall be indicated on FRA Form F 6180-49A. 

 

§ 229.105 Steam generator number. 

An identification number shall be marked on the steam generator’s separator and that number 

entered on FRA Form F 6180-49A. 

 

§ 229.107 Pressure gauge. 

(a) Each steam generator shall have an illuminated steam gauge that correctly indicates 

the pressure. The steam pressure gauge shall be graduated to not less than one and onehalf times the allowed working pressure of the steam generator. 

(b) Each steam pressure gauge on a steam generator shall have a siphon that prevents 

steam from entering the gauge. The pipe connection shall directly enter the separator and 

shall be steam-tight between the separator and the gauge. 

§ 229.109 Safety valves. 

Every steam generator shall be equipped with at least two safety valves that have a combined 

capacity to prevent an accumulation of pressure of more than five pounds per square inch above 

the allowed working pressure. The safety valves shall be independently connected to the 

separator and located as closely to the separator as possible without discharging inside of the 

generator compartment. The ends of the safety valve discharge lines shall be located or 

protected so that discharged steam does not create a hazard. 

§ 229.111 Water-flow indicator. 

(a) Steam generators shall be equipped with an illuminated visual return water-flow 

indicator. 

(b) Steam generators shall be equipped with an operable test valve or other means of 

determining whether the steam generator is filled with water. The fill test valve may not 

discharge steam or hot water into the steam generator compartment. 

§ 229.113 Warning notice. 
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Whenever any steam generator has been shut down because of defects, a distinctive warning 

notice giving reasons for the shut-down shall be conspicuously attached near the steam generator 

starting controls until the necessary repairs have been made. The locomotive in which the steam 

generator displaying a warning notice is located may continue in service until the next periodic 

inspection. 

Guidance

The steam generator regulations are not included in their entirety because there are none in 

service at the present time. The inspector should refer to the current part 229 if a steam 

generator is found in service in his/her district. 

Amtrak and the commuter railroads use electricity to heat the passenger cars, operate air 

conditioning units, provide train lighting, and for all other ancillary equipment. The power 

source is usually a generator installed in the diesel-electric locomotive or an inverter in the 

electric current. Generators could be a stand-alone engine/generator unit located in a car, in an 

auxiliary car, or in a compartment of the locomotive. This equipment is to be inspected by the 

FRA inspectors. It is the railroad’s responsibility to maintain the equipment in a safe and 

suitable condition for service and all deficiencies should be reported under § 229.45. 

§ 229.115 Slip/slide alarms. 

(a) Except for MU locomotives, each locomotive used in road service shall be equipped 

with a device that provides an audible or visual alarm in the cab of either slipping or 

sliding wheels on powered axles under power. When two or more locomotives are 

coupled in multiple or remote control, the wheel slip/slide alarm of each locomotive shall 

be shown in the cab of the controlling locomotive. 

(b) Except as provided in § 229.9, an equipped locomotive may not be dispatched in road 

service, or continue in road service following a daily inspection, unless the wheel 

slip/slide protective device of whatever type -- 

(1) Is functioning for each powered axle under power; and 

(2) Would function on each powered axle if it were under power. 

(c) Effective January 1, 1981, all new locomotives capable of being used in road service 

shall be equipped with a device that detects wheel slip/slide for each powered axle when 

it is under power. The device shall produce an audible or visual alarm in the cab. 

Guidance

On most DC-powered traction motors, the slip/slide device is nullified when a traction motor is 

cut-out. Therefore, movement of a locomotive with a DC traction motor cut-out can only be 

made under the provisions of § 229.9. GE provided information concerning wheel slip slide and 

wheel lock protection provided on the GE Dash 8 and Dash 9 locomotive models. These wheel 
Motive Power and Equipment Compliance Manual 

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slip /wheel lock devices function independent of the DC electrical energy provided to power the 

traction motors. FRA determined that since the wheel slip/slide detection remains fully active, 

even though one or more of the traction motors are cut-out, it is not a safety related item and is in 

proper condition and safe to operate without unnecessary peril to life and limb under 49 CFR § 

229.7. This condition also meets the requirements for slip/slide alarms under 49 CFR § 229.115. 

Being consistent with its enforcement guidance and policies relating to wheel slip/slide and 

wheel lock on alternating current locomotives, FRA takes no exception to the continued use of 

locomotives with wheel slip/slide alarms described above provided all of the following 

conditions are met: 

1. Locomotives so equipped will not be permitted to operate with defective or 

cut-out traction motors beyond any periodic inspection required under 49 CFR § 

229.23. 

2. Any railroad operating such locomotives must clearly identify within the 

operating cab of the locomotive that the locomotive is using the wheel slip/slide 

design as described in this letter within the operating cab of the locomotive. 

Locomotives operating with AC traction motors have a wheel slip/slide detection system that 

remains active regardless of whether an inverter and related traction motor is cut-out. With the 

slip/slide system active, FRA has determined that a cut-out AC traction motor/inverter is not a 

safety-related item, and does not take exception to the continued use of locomotives with the AC 

traction motor cut-out, provided the locomotives does not operate with the defective or cut-out 

traction motor beyond the periodic inspection required under § 229.23. This applies to both GE 

and EMD locomotives. 

Section (a): The wheel slip/slide device must be provided with either an audible or visual alarm 

in the cab; only one is required. In a multiple-locomotive consist, the wheel slip/slide action that 

may occur on a trailing locomotive or on a remote-controlled locomotive must activate a device 

that can be heard or seen in the cab of the controlling locomotive. This also applies to 

locomotives operating in DPU service. 

Section (b): The exclusion to this requirement is included in Section 229.101(b) and (c). 

Section (c): Only MU locomotives built prior to January 1, 1981, are excluded from this rule. 

MU locomotives built after this date must be equipped as required by Section (a). All MU 

locomotives that have powered wheels equipped with slip/slide protection must maintain and 

have such equipment in operating condition. 

 

§ 229.117 Speed indicators. 

(a) After December 31, 1980, each locomotive used as a controlling locomotive at speeds 

in excess of 20 miles per hour shall be equipped with a speed indicator which is -- 

 
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(1) Accurate within ±3 miles per hour of actual speed at speeds of 10 to 30 miles 

per hour and accurate within ±5 miles per hour at speeds above 30 miles per hour; 

and 

(2) Clearly readable from the engineer’s normal position under all light 

conditions. 

(b) Each speed indicator required shall be tested as soon as possible after departure by 

means of speed test sections or equivalent procedures. 

Guidance

Section (a): The inspector must recognize that this regulation has several qualifiers: (1) the 

locomotive must be a controlling locomotive, and (2) it must be on a train that will exceed a 

speed of 20 mph. These two criteria must be met before enforcement procedures can be 

instituted. If a locomotive is placed in service in a non-controlling position without a speed 

indicator or an inoperative speed indicator, the locomotive is in compliance with this section. 

This section applies to MU locomotives, and when it was promulgated FRA informed the 

affected commuter lines that they could apply for waivers. 

Section (b): If a speed indicator of a controlling locomotive becomes inoperative en route, it 

may continue in service under the provision of Section 229.9. It does not require the railroad to 

reduce the train speed to 20 mph or less. If the noncomplying condition can be brought into 

compliance by shifting the position of the locomotive in the consist, the noncomplying condition 

should be rectified by doing so at the next forward location. This could be a siding, a wye, or 

any location where it is physically possible to reposition the locomotive without endangering the 

safety of employees, locomotives, or trains. (MP&E 98-50)

If the inspector can develop a case in which a railroad dispatched a controlling locomotive with a 

reported defective speed indicator, suitable enforcement action should be taken. 

§ 229.119 Cabs, floors, and passageways. 

(a) Cab seats shall be securely mounted and braced. Cab doors shall be equipped with a 

secure and operable latching device. 

(b) Cab windows of the lead locomotive shall provide an undistorted view of the right-ofway for the crew from their normal position in the cab. (See also, Safety Glazing 

Standards, 49 CFR Part 223, 44 FR 77348, Dec. 31, 1979.) 

(c) Floors of cabs, passageways, and compartments shall be kept free from oil, water, 

waste or any obstruction that creates a slipping, tripping or fire hazard. Floors shall be 

properly treated to provide secure footing. 
Motive Power and Equipment Compliance Manual 

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(d) The cab shall be provided with proper ventilation and with a heating arrangement that 

maintains a temperature of at least 50 degrees Fahrenheit six (6) inches above the center 

of each seat in the cab. 

(e) Similar locomotives with open end platforms coupled in multiple controls and used in 

road service shall have a means of safe passage between them; no passageway is required 

through the nose of car body locomotives. There shall be a continuous barrier across the 

full width of the end of a locomotive or a continuous barrier between locomotives. 

(f) Containers shall be provided for carrying fusees and torpedoes. A single container 

may be used if it has a partition to separate fusees from torpedoes. Torpedoes shall be 

kept in a closed metal container. 

 

Guidance 

Section (a): Cab seats should be reported as defective only when they are not securely mounted 

and braced. Wall-mounted seat bracket guideways should have no openings in them that would 

allow the seat bracket to inadvertently fall out. Hydraulic cab seats should be checked for 

operation and leaks. 

Section (b): Cab window defects can only be reported if they interfere with the crew’s 

undistorted view of the right-of-way from their normal seated position in the cab. This is a 

performance standard that should be sufficient to require the railroads to properly maintain such 

things as windshield wipers and defrosters to meet this standard. Defective cab windows for any 

other reason may either be taken under the glazing regulations found in part 223, or under 

section 229.45, if broken and sharp edges create a personal injury hazard. 

Section (c): Accumulations of oil, water, debris, and other items on passageway, walkways, cab 

control compartment floors, or engine compartment floors should be of such a nature as to 

present a potential hazard and unsafe condition for any person who would use them (e.g., 

slipping, tripping, or does not provide secure footing). When an inspector discovers these 

conditions, he/she should also determine the source and take appropriate enforcement action. 

The regulation does not require that such things as portable ice chests or crew luggage be secured 

in the cab, but if these items create a personal injury hazard they should be addressed. 

Locomotive air compressor compartments are routinely used for the storage of tools and 

materials for servicing the locomotive and train (e.g., air hoses, jumper cables, wrenches, etc.), 

thereby requiring train crew members to enter the air compressor compartment to retrieve many 

of these items. If the floor in the air compressor compartment is cluttered with loose material or 

is covered with oil, a tripping or slipping hazard exists. 

Several railroads are currently installing toolboxes on their locomotives in the doorway leading 

into the air compressor compartment. The toolbox location is identified and all other doors 

leading into the air compressor compartment are marked for maintenance personnel only. The 

railroad believes that by removing the tools from the compartment and denying access to all 

except maintenance personnel, the slipping hazard has been removed. In addition, maintenance 
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personnel entering the compartment are required to inspect the floor first and then remove any 

slipping or tripping hazard prior to entry. 

In late 1999, an MP&E Technical Resolution Committee (TRC) examined the application of § 

229.119(c) relevant to air compressor compartments, in light of the scenario noted above. Based 

on the discussions and recommendations developed by the TRC, FRA has determined that the 

presence of oil on the floor of the locomotive air compressor compartment does not constitute a 

slipping or tripping hazard under § 229.119(c), if all of the following conditions are complied 

with: 

1. Train crews are prohibited from entering the air compressor compartment by general 

order, bulletin order, time table instructions, or other formal instructions. 

2. The air compressor compartment doors are stenciled to indicate that train crew 

members are not to enter the compartments. 

3. Tool storage compartments are readily and clearly identified by stencils. 

4. Tool storage compartments are self-contained units, arranged and designed so that 

any tools or materials falling from the storage hooks or racks do not fall onto the floor of 

air compressor compartment. 

5. When a train crew member identifies (without entering the compartment) a slipping 

hazard in the air compressor compartment, the condition is listed on the inspection report 

(current or next daily). Identification of such a condition should not be treated as a 

noncomplying condition under Part 229 if all other conditions contained in this bulletin 

are otherwise met. 

6. When any tools or materials intended for use by the train crew are found on the air 

compartment floor, the condition is treated as a tripping hazard, a noncomplying 

condition under § 229.119(c), and corrective action is taken. 

7. Railroads should continue to clean the air compressor compartment as necessary in a 

timely fashion. 

 

FRA inspectors should take appropriate enforcement action, if there is oil on the air compressor 

compartment floor that creates a slippery condition and there is a tool, part, or material inside 

that may be needed by a train crew member, even though all other conditions noted above have 

been met (i.e., restricted access, separate tool storage compartment area). 

Furthermore, if the locomotive is not properly stenciled, as noted above, or the train crew is 

unaware of the access restrictions to the air compressor compartment, then any loose material or 

oil on the air compressor compartment floor that creates a slipping or tripping hazard would 

constitute noncompliance with § 229.119(c), and appropriate enforcement action should be 

taken. (MP&E 00-05)
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Section (e): The regulation does not require that a locomotive connected with another 

locomotive has to have an open-end platform. It only requires that if the locomotive does not 

have a continuous barrier, such as a solid handrail, then the passage between the two locomotives 

must be safe and protected by chains or other devices. Continuous barriers missing should not 

be reported as a defect if the locomotive is not being used and is inspected in a locomotive 

service facility. Although there are no minimum height restrictions when a chain is used, 

inspectors should ensure the chain does not present a tripping hazard. 

§ 229.121 Locomotive cab noise. 

(a) Performance Standards for Locomotives. 

(1) When tested for static noise in accordance with paragraph (a)(3) of this section, all 

locomotives of each design or model that are manufactured after October 29, 2007, shall 

average less than or equal to 85 dB(A), with an upper 99% confidence limit of 87 dB(A). 

The railroad may rely on certification from the equipment manufacturer for a production 

run that this standard is met. The manufacturer may determine the average by testing a 

representative sample of locomotives or an initial series of locomotives, provided that 

there are suitable manufacturing quality controls and verification procedures in place to 

ensure product consistency. 

(2) In the maintenance of locomotives that are manufactured in accordance with 

paragraph (a)(1) of this section, a railroad shall not make any alterations that cause the 

average sound level for that locomotive design or model to exceed: 

 

(i) 82 dB(A) if the average sound level for a locomotive design or model is less 

than 82 dB(A); or 

 

(ii) 85 dB(A) if the average sound level for a locomotive design or model is 82 

dB(A) to 85 dB(A), inclusive, 

 (3) The railroad or manufacturer shall follow the static test protocols set forth in 

appendix H of this part to determine compliance with paragraph (a)(1) of this section; 

and, to the extent reasonably necessary to evaluate the effect of alterations during 

maintenance, to determine compliance with paragraph (a)(2) of this section. 

 (b) Maintenance of Locomotives. 

(1) If a railroad receives an excessive noise report, and if the condition giving rise to the 

noise is not required to be immediately corrected under part 229, the railroad shall 

maintain a record of the report, and repair or replace the item identified as substantially 

contributing to the noise: 

 

(i) on or before the next periodic inspection required by § 229.23; or 
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(ii) if the railroad determines that the repair or replacement of the item requires 

significant shop or material resources that are not readily available, at the time of 

the next major equipment repair commonly used for the particular type of 

maintenance needed. 

 (2) Conditions that may lead a locomotive cab occupant to file an excessive noise report 

include, but are not limited to: defective cab window seals; defective cab door seals; 

broken or inoperative windows; deteriorated insulation or insulation that has been 

removed for other reasons; broken or inoperative doors; and air brakes that vent inside of 

the cab. 

 (3) A railroad has an obligation to respond to an excessive noise report that a locomotive 

cab occupant files. The railroad meets its obligation to respond to an excessive noise 

report, as set forth in paragraph (b)(1) of this section, if the railroad makes a good faith 

effort to identify the cause of the reported noise, and where the railroad is successful in 

determining the cause, if the railroad repairs or replaces the items cause the noise. 

 (4) Recordkeeping. 

(i) A railroad shall maintain a written or electronic record of any excessive noise 

report, inspection, test, maintenance, replacement, or repair completed pursuant to 

§ 229.121(b) and the date on which that inspection, test, maintenance, 

replacement, or repair occurred. If a railroad elects to maintain an electronic 

record, the railroad must satisfy the conditions listed in § 227.121(a)(2)(i) 

through (v). 

(ii) The railroad shall retain these records for 92 days if they are made pursuant to 

§ 229.21, or for one year if they are made pursuant to § 229.23. 

(iii)The railroad shall establish an internal, auditable, monitorable system that 

contains these records. 

 

Guidance 

(TBD) 

§ 229.123 Pilots, snowplows, end plates. 

After January 1, 1981, each lead locomotive shall be equipped with an end plate that extends 

across both rails, a pilot, or a snowplow. The minimum clearance above the rail of the pilot, 

snowplow or end plate shall be 3 inches, and the maximum clearance six (6) inches. 

Guidance 
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This section also applies to MU locomotives. Keep in mind, several railroads have been granted 

conditional waivers that allow the maximum height to be greater than 6 inches for locomotives 

used in hump yard service. For a locomotive consist, this requirement only applies to the lead 

locomotive. The measurement should be taken on relatively level track. The inspector should 

not defect a locomotive for a minimal deviation of the height requirement. The railroad should 

be told to adjust the end arrangement so that it is in compliance. 

§ 229.125 Headlights and auxiliary lights. 

(a) Each lead locomotive used in road service shall have a headlight that produces a peak 

intensity of at least 200,000 candela. If a locomotive or locomotive consist in road service 

is regularly required to run backward for any portion of its trip other than to pick up a 

detached portion of its train or to make terminal movements, it shall also have on its rear 

a headlight that produces at least 200,000 candela. Each headlight shall be arranged to 

illuminate a person at least 800 feet ahead and in front of the headlight. For purposes of 

this section, a headlight shall be comprised of either one or two lamps. 

(1) If a locomotive is equipped with a single lamp headlight, the single lamp shall 

produce a peak intensity of at least 200,000 candela. The following meet the 

standard set forth in this paragraph (a)(1): a single PAR-56, 200 watt, 30-volt 

lamp; or a lamp of equivalent design and intensity. 

(2) If a locomotive is equipped with a dual-lamp headlight, a peak intensity of 

200,000 candela shall be produced by the headlight based either on a single lamp 

capable of individually producing the required peak intensity or on the candela 

produced by the headlight with both lamps illuminated. If both lamps are needed 

to produce the required peak intensity, then both lamps in the headlight shall be 

operational. The following meet the standard set forth in this paragraph (a)(2): a 

single PAR-56, 200-watt, 30-volt lamp; two operative PAR-56, 350-watt, 75-volt 

lamps; or a lamp(s) of equivalent design and intensity. 

(b) Each locomotive or locomotive consist used in yard service shall have two headlights, 

one located on the front of the locomotive or locomotive consist and one on its rear. Each 

headlight shall produce at least 60,000 candela and shall be arranged to illuminate a 

person at least 300 feet ahead and in front of the headlight. 

(c) Headlights shall be provided with a device to dim the light. 

(d) Effective December 31, 1997, each lead locomotive operated at a speed greater than 

20 miles per hour over one or more public highway-rail crossings shall be equipped with 

operative auxiliary lights, in addition to the headlight required by paragraph (a) or (b) of 

this section. A locomotive equipped on March 6, 1996 with auxiliary lights in 

conformance with § 229.133 shall be deemed to conform to this section until March 6, 

2000. All locomotives in compliance with § 229.133(c) shall be deemed to conform to 

this section. Auxiliary lights shall be composed as follows: 
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(1) Two (2) white auxiliary lights shall be placed at the front of the locomotive to 

form a triangle with the headlight. 

(i) The auxiliary lights shall be at least 36 inches above the top of the rail, 

except on MU locomotives and control cab locomotives where such 

placement would compromise the integrity of the car body or be otherwise 

impractical. Auxiliary lights on such MU locomotives and control cab 

locomotives shall be at least 24 inches above the top of the rail. 

(ii) The auxiliary lights shall be spaced at least 36 inches apart if the 

vertical distance from the headlight to the horizontal axis of the auxiliary 

lights is 60 inches or more. 

(iii) The auxiliary lights shall be spaced at least 60 inches apart if the 

vertical distance from the headlight to the horizontal axis of the auxiliary 

lights is less than 60 inches. 

(2) Each auxiliary light shall produce a peak intensity of at least 200,000 candela 

or shall produce at least 3,000 candela at an angle of 7.5 degrees and 400 candela 

at an angle of 20 degrees from the centerline of the locomotive when the light is 

aimed parallel to the tracks. Any of the following meet the standard set forth in 

this paragraph (d)(2): a PAR-56, 200-watt, 30-volt lamp; a PAR-56, 350-watt, 75-

volt lamp; or a lamp of equivalent design and intensity. 

(3) The auxiliary lights shall be focused horizontally within 15 degrees of the 

longitudinal centerline of the locomotive. 

(e) Auxiliary lights required by paragraph (d) of this section may be arranged 

(1) to burn steadily or 

(2) flash on approach to a crossing. If the auxiliary lights are arranged to flash; 

(i) they shall flash alternately at a rate of at least 40 flashes per minute and 

at most 180 flashes per minute, 

(ii) the railroad’s operating rules shall set a standard procedure for use of 

flashing lights at public highway-rail grade crossings, and 

(iii) the flashing feature may be activated automatically, but shall be 

capable of manual activation and deactivation by the locomotive engineer. 

(f) Auxiliary lights required by paragraph (d) of this section shall be continuously 

illuminated immediately prior to and during movement of the locomotive, except as 

provided by railroad operating rules, timetable or special instructions, unless such 

exception is disapproved by FRA. A railroad may except use of auxiliary lights at a 
Motive Power and Equipment Compliance Manual 

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specific public highway-rail grade crossing by designating that exception in the railroad’s 

operating rules, timetable, or a special order. Any exception from use of auxiliary lights 

at a specific public grade crossing can be disapproved for a stated cause by FRA’s 

Associate Administrator for Safety or any one of FRA’s Regional Administrators, after 

investigation by FRA and opportunity for response from the railroad. 

(g) Movement of locomotives with defective auxiliary lights. 

(1) A lead locomotive with only one failed auxiliary light must be repaired or 

switched to a trailing position before departure from the place where an initial 

terminal inspection is required for that train. 

(2) A locomotive with only one auxiliary light that has failed after departure from 

an initial terminal, must be repaired not later than the next calendar inspection 

required by § 229.21. 

(3) A lead locomotive with two failed auxiliary lights may only proceed to the 

next place where repairs can be made. This movement must be consistent with 

§ 229.9. 

(h) Any locomotive subject to part 229, that was built before December 31, 1948, and 

that is not used regularly in commuter or intercity passenger service, shall be considered 

historic equipment and excepted from the requirements of paragraphs (d) through (h) of 

this section. 

Guidance 

The candela rating established in this section corresponds to the intensity level implicitly 

required under the prior rules in part 230. That rule was more a detailed performance standard 

that required not only that it illuminate a person 800 feet ahead and in front of the headlight, but 

that the engineer in the operating compartment possess the visual capacity to see in a clear 

atmosphere a dark object as large as a man of average size standing erect at least 800 feet ahead 

and in front of the headlight. 

The inspector should also be aware that the qualifier in this section is that only the lead 

locomotive must be equipped with the prescribed headlight. Intermediate locomotives in a 

consist with inoperative headlights are not to be considered as noncomplying. Also, the 

requirement for rear headlights on road locomotives has certain conditions. The inspector should 

take appropriate enforcement action when a headlight is found defective. However, if the 

locomotive has a light arrangement using two sealed beam headlights, the inspector must 

ascertain whether they are the 200-watt, 30-volt lamps or if they are the 350-watt, 75-volt lamps. 

The reason for this is because if the dual light system is using the 200-watt, 30-volt lamps, both 

lamps would have to be defective before enforcement action can be taken. However, the 

inspector should take appropriate enforcement action if one of the bulbs is defective on dual-light 

systems using the 350-watt, 75-volt lamps. 
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There have been instances where some locomotives have had the auxiliary lights (ditch lights) 

installed in a manner that covers a portion of the uncoupling levers, which serve as the end 

handhold on a locomotive. If this condition exists, it should be handled for correction. 

The following questions and answers are from a previously issued Technical Bulletin that 

addressed the many inquiries concerning the application, operation, and inspection requirements 

of auxiliary lights: 

1. When does a locomotive have to be equipped with auxiliary lights? 

A. Each lead locomotive that operates over one or more public grade crossings at a 

speed greater than 20 mph shall be equipped with operative auxiliary lights on 

the forward end of the locomotive as it approaches a public highway-rail grade 

crossing. 

2. What is a public highway-rail grade crossing as it applies to auxiliary lights? 

A. It is the location where railroad tracks intersect a roadway that is part of the 

general system of public streets and highways, and is under the jurisdiction of and 

maintained by a public authority and open to the general traveling public. 

3. What are auxiliary lights? 

A. Auxiliary lights are two white lights producing at least 200,000 candela that are 

located on the front of the locomotive to form a triangle with the locomotive 

headlight. They must be mounted at least 36 inches above the top of the rail, except 

on MU locomotives and control cab locomotives where such placement would be 

impractical. On such MU locomotives and cab control locomotives, the lights shall 

be mounted at least 24 inches above the top of the rail. Other mounting and 

focusing requirements are listed in § 229.125(d). There are other arrangements that 

are “grandfathered” to satisfy auxiliary light requirements.

4. What are the grandfathered arrangements? 

A. 1). Oscillating lights may fulfill the requirements of section 229.125(d) 

for auxiliary lights, provided they meet the “grandfathering” requirement 

of section 229.133(c)(1), i.e. the oscillating light meets the requirements of 

section 229.133(b)(4)(A) or (B), and was “ordered for installation on that 

locomotive prior to January 1, 1996. 

2) Note that Part 229.133(b)(4)(A) refers to a traditional mechanically 

oscillating light (Marrs or Gyra style lights), whereas section 

229.133(b)(4)(B) refers to electrically oscillating (alternately flashing) 

lights “at one location on the front of the locomotive” (not separated as 

regular auxiliary lights would be) aimed within 5 degrees of the centerline 
Motive Power and Equipment Compliance Manual 

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of the locomotive. If it was installed after January 1, 1996, it does not 

qualify. 

3) Strobe lights that were applied to the locomotive prior to March 6, 

1996, will satisfy the auxiliary light requirements until the locomotive is 

either retired or rebuilt (whichever comes first), but the speed of the 

locomotive is restricted to 40 mph when used as a lead locomotive. 

4) Two white auxiliary lights spaced at least 44 inches apart on at least 

one axis, and that were installed on the locomotive prior to May 30, 1994, 

satisfies the auxiliary light requirements until the locomotive is either 

rebuilt or retired, whichever comes first. This is the headlight 

arrangement commonly used in commuter service.

5. Do auxiliary lights have to work when a calendar-day inspection is performed? 

 A. Auxiliary lights are treated the same as headlights when calendar-day 

inspections are performed. 

6. When do the auxiliary lights have to be illuminated? 

A. Auxiliary lights must remain continuously illuminated immediately prior to and 

during the movement of the locomotive, except as provided by railroad operating 

rules, timetables, or special instructions. This not only increases conspicuity at 

public highway-rail grade crossings, but also addresses private crossings, 

pedestrians, and roadway workers. 

7. Do the lights have to flash on approaching a crossing? 

A. The lights may burn steadily or flash (pulse) on approach and while passing 

over a public highway-rail grade crossing. 

8. Are there circumstances where the lights can be legally extinguished? 

A. Yes. The regulations permit railroads to designate specific locations where 

auxiliary lights can be extinguished, as long as these designated locations are 

identified in either the railroad’s operating rules, timetable, or special written 

instructions. This would typically be at locations where existing operating rules 

require the headlight to be dimmed, such as: at stations; when passing another 

train; in yards where switching is performed; or at locations where train operations 

parallel a public highway and the night vision of motorists would be impaired by 

the use of auxiliary lights. Any exceptions from the use of auxiliary lights at 

specific locations are subject to disapproval by FRA’s Associate Administrator for 

Railroad Safety/Chief Safety Officer, or one of FRA’s Regional Administrators, 

after the investigation, and an opportunity for response by the railroad, for a stated 

good cause. 
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9. Can a train be dispatched from the initial terminal without auxiliary lights on 

the lead locomotive? 

A. If the lead locomotive is not equipped with auxiliary lights, the train can be 

dispatched out of an initial terminal, with the understanding that the locomotive 

cannot operate over any public highway-rail grade crossing at a speed greater than 

20 mph. Otherwise, if the lead locomotive is equipped with auxiliary lights, all

must be functioning on the end of the locomotive in the forward direction of the 

train movement. 

10. Can the train leave the initial terminal with one light defective on the lead 

locomotive? 

A. No, all auxiliary lights must be working on the lead locomotive in the forward 

direction of the train movement. 

11. What about en route failures? 

A. If one light becomes defective en route, the locomotive can continue to operate 

in the lead at track speed, but the defective light must be repaired no later than the 

next calendar day. This locomotive could not be used in the lead position out of an 

initial terminal unless repairs were made. If two lights become defective en route, 

the locomotive (train) may only proceed to the next location where repairs can be 

made, and the locomotive is restricted to 20 mph or less over all public highway-rail 

grade crossings until the lights are functioning.

12. If the mechanism that causes the oscillating light to oscillate is defective, how 

should this condition be treated? 

A. This would be treated as a complete failure of the auxiliary light. It could not be 

dispatched from an initial terminal as a lead unit, and if the failure occurred en 

route, it would have to be repaired at the next point where repairs could be made 

with the locomotive restricted to 20 miles per hour over all public highway-rail 

grade crossings. 

13. Are locomotives that operate in both directions (dual-control) required to be 

equipped with auxiliary lights on each end of the locomotive? 

A. These types of locomotives should be equipped on each end, since they 

frequently operate as a lead in both directions. However, if a locomotive is 

equipped with auxiliary lights on only one end, then it could only be dispatched out 

of an initial terminal as the lead unit, if the equipped end is placed in the forward 

direction of the train movement. If during the trip this same locomotive made a 

reverse move as a lead unit, it would be restricted to 20 miles per hour over all 

public highway-rail grade crossings. 
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14. When a speed restriction at a public highway-rail grade crossing is required, 

does this mean the whole train is restricted to 20 miles per hour over the crossing? 

A No, just the lead locomotive is restricted to 20 miles per hour over the crossing. 

15. Are steam locomotives required to be equipped with auxiliary lights? 

A. No. Also, any locomotive built before December 31, 1948, which is not used in 

commuter or inter-city passenger service, is excepted from auxiliary light 

requirements. (MP&E 98-3) 

§ 229.127 Cab lights. 

(a) Each locomotive shall have cab lights which will provide sufficient illumination for 

the control instruments, meters, and gauges to enable the engine crew to make accurate 

readings from their normal positions in the cab. These lights shall be located, constructed, 

and maintained so that light shines only on those parts requiring illumination and does 

not interfere with the crew’s vision of the track and signals. Each controlling locomotive 

shall also have a conveniently located light that can be readily turned on and off by the 

persons operating the locomotive and that provides sufficient illumination for them to 

read train orders and timetables. 

 (b) Cab passageways and compartments shall have adequate illumination. 

Guidance 

Section (b): The preamble to this rule states that it was intended to be similar to the former rule, 

230.233(b), which includes the qualifier that when employees are required to pass from one cab 

to another, the platform and passageway between shall be illuminated. There are no 

passageways on the road-switcher type of locomotives; these are found on the car body type 

locomotives where people walk inside and illumination is important. Lights that are inside the 

car body of a road-switcher type locomotive are not to be considered as compartment lights and 

shall not be taken as a noncomplying condition. Where the criteria for a passageway exist, 

illumination must be provided and the lights maintained. The same is true for the walkway 

platforms between locomotives found on road-switchers. A flashlight or other hand-held light 

does not satisfy the requirements of this rule. 

§ 229.129 Locomotive horn. 

(a) Each lead locomotive shall be equipped with a locomotive horn that produces a 

minimum sound level of 96 dB(A) and a maximum sound level of 110 dB(A) at 100 feet 

forward of the locomotive in its direction of travel. The locomotive horn shall be 

arranged so that it can be conveniently operated from the engineer's usual position during 

operation of the locomotive. 
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 (b) 

(1) Each locomotive built on or after September 18, 2006 shall be tested in 

accordance with this section to ensure that the horn installed on such locomotive 

is in compliance with paragraph (a) of this section. Locomotives built on or after 

September 18, 2006 may, however, be tested in accordance with an acceptance 

sampling scheme such that there is a probability of .05 or less of rejecting a lot 

with a proportion of defectives equal to an AQL of 1% or less, as set forth in 7 

CFR part 43. 

(2) Each locomotive built before September 18, 2006 shall be tested in 

accordance with this section before June 24, 2010 to ensure that the horn installed 

on such locomotive is in compliance with paragraph (a) of this section. 

 

(3) Each remanufactured locomotive, as determined pursuant to § 229.5 of this 

part, shall be tested in accordance with this section to ensure that the horn 

installed on such locomotive is in compliance with paragraph (a). 

 (4) 

(i) Except as provided in paragraph (b)(4)(ii) of this section, each 

locomotive equipped with a replacement locomotive horn shall be tested, 

in accordance with paragraph (c) of this section, before the next two 

annual tests required by § 229.27 of this part are completed. 

(ii) Locomotives that have already been tested individually or through 

acceptance sampling, in accordance with paragraphs (b)(1), (b)(2), or 

(b)(3) of this section, shall not be required to undergo sound level testing 

when equipped with a replacement locomotive horn, provided the 

replacement locomotive horn is of the same model as the locomotive horn 

that was replaced and the mounting location and type of mounting are the 

same. 

(c) Testing of the locomotive horn sound level shall be in accordance with the following 

requirements: 

(1) A properly calibrated sound level meter shall be used that, at a minimum, 

complies with the requirements of International Electrotechnical Commission 

(IEC) Standard 61672-1 (2002-05) for a Class 2 instrument. 

(2) An acoustic calibrator shall be used that, at a minimum, complies with the 

requirements of IEC standard 60942 (1997-11) for a Class 2 instrument. 

(3) The manufacturer's instructions pertaining to mounting and orienting the 

microphone; positioning of the observer; and periodic factory recalibration shall 

be followed. 
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(4) A microphone windscreen shall be used and tripods or similar microphone 

mountings shall be used that minimize interference with the sound being 

measured. 

(5) The test site shall be free of large reflective structures, such as barriers, hills, 

billboards, tractor trailers or other large vehicles, locomotives or rail cars on 

adjacent tracks, bridges or buildings, within 200 feet to the front and sides of the 

locomotive. The locomotive shall be positioned on straight, level track. 

(6) Measurements shall be taken only when ambient air temperature is between 32 

degrees and 104 degrees Fahrenheit inclusively; relative humidity is between 20 

percent and 95 percent inclusively; wind velocity is not more than 12 miles per 

hour and there is no precipitation. 

(7) With the exception of cab-mounted or low-mounted horns, the microphone 

shall be located 100 feet forward of the front knuckle of the locomotive, 15 feet 

above the top of the rail, at an angle no greater than 20 degrees from the center 

line of the track, and oriented with respect to the sound source according to the 

manufacturer's recommendations. For cab-mounted and low-mounted horns, the 

microphone shall be located 100 feet forward of the front knuckle of the 

locomotive, four feet above the top of the rail, at an angle no greater than 20 

degrees from the center line of the track, and oriented with respect to the sound 

source according to the manufacturer's recommendations. The observer shall not 

stand between the microphone and the horn. 

(8) Background noise shall be minimal: the sound level at the test site 

immediately before and after each horn sounding event shall be at least 10 dB(A) 

below the level measured during the horn sounding. 

(9) Measurement procedures. The sound level meter shall be set for A-weighting 

with slow exponential response and shall be calibrated with the acoustic calibrator 

immediately before and after compliance tests. Any change in the before and after 

calibration levels shall be less than 0.5 dB. After the output from the locomotive 

horn system has reached a stable level, the A-weighted equivalent sound level 

(slow response) for a 10-second duration (LAeq, 10s) shall be obtained either 

directly using an integrating-averaging sound level meter, or recorded once per 

second and calculated indirectly. The arithmetic-average of a series of at least six 

such 10-second duration readings shall be used to determine compliance. The 

standard deviation of the readings shall be less than 1.5 dB. 

(10) Written reports of locomotive horn testing required by this part shall be made 

and shall reflect horn type; the date, place, and manner of testing; and sound level 

measurements. These reports, which shall be signed by the person who performs 

the test, shall be retained by the railroad, at a location of its choice, until a 

subsequent locomotive horn test is completed and shall be made available, upon 

request, to FRA as provided by 49 U.S.C. 20107. 
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(d) This section does not apply to locomotives of rapid transit operations which are 

otherwise subject to this part. 

Guidance

(TBD) 

§ 229.131 Sanders. 

Except for MU locomotives, each locomotive shall be equipped with operable sanders that 

deposit sand on each rail in front of the first power operated wheel set in the direction of 

movement. 

Guidance

The section has two qualifiers, in that MU locomotives are exempt and that each locomotive in 

a consist shall have operable sanders that deposit sand in front of the first power-operated 

wheel set in the direction of movement. At a servicing facility where the direction of a 

locomotive or locomotive consist is unknown, the inspector should require the railroad to have 

all out-board sanders operational prior to departure. However, if a locomotive is inspected at the 

head end of the train, only the sanders in the direction of the train movement must be 

operational. Locomotives used in yard switching service, which normally move in both 

directions, should have the outboard sanders operational. A hole in the sand delivery pipe is not 

an inoperative sander. The mere presence of a hole in the sander hose or pipe is not sufficient to 

establish a violation under section 229.131, without detailed discussion of the hole’s impact on 

the sander’s ability to operate. FRA is required to establish that the sander is not depositing sand 

in front of the wheel. However, if sand is being discharged at eye level and constitutes a 

personal injury hazard, it should be reported under section 229.45. 

§ 229.133 Interim locomotive conspicuity measures -- auxiliary external lights. 

Guidance

Guidance for this section can be found under § 229.125, Headlights and auxiliary lights.

§ 229.135 Event recorders. 

 

(a) Duty to equip and record. Except as provided in paragraphs (c) and (d) of this 

section, a train operated faster than 30 miles per hour shall have an in-service event 

recorder, of the type described in paragraph (b) of this section, in the lead locomotive. 

The presence of the event recorder shall be noted on Form FRA F6180-49A (by writing 

the make and model of event recorder with which the locomotive is equipped) under the 

REMARKS section, except that an event recorder designed to allow the locomotive to 
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assume the lead position only if the recorder is properly functioning is not required to 

have its presence noted on Form FRA F6180-49A. For the purpose of this section, 

“train’’ includes a locomotive or group of locomotives with or without cars. The duty to 

equip the lead locomotive may be met with an event recorder located elsewhere than the 

lead locomotive provided that such event recorder monitors and records the required data 

as though it were located in the lead locomotive. The event recorder shall record the 

most recent 48 hours of operation of the electrical system of the locomotive on which it is 

installed. 

(b) Equipment requirements. Event recorders shall monitor and record data elements 

required by this paragraph with at least the accuracy required of the indicators displaying 

any of the required elements to the engineer. 

(1) A lead locomotive originally ordered before October 1, 2006, and placed in 

service before October 1, 2009, including a controlling remote distributed power 

locomotive, a lead manned helper locomotive, a DMU locomotive, and an MU 

locomotive, except as provided in paragraphs (c) and (d) of this section, shall 

have an in-service event recorder that records the following data elements: 

(i) Train speed; 

(ii) Selected direction of motion; 

(iii) Time; 

(iv) Distance; 

(v) Throttle position; 

(vi) Applications and operations of the train automatic air brake; 

(vii) Applications and operations of the independent brake; 

 

(viii) Applications and operations of the dynamic brake, if so equipped; 

and 

(ix) Cab signal aspect(s), if so equipped and in use. 

(2) A locomotive originally manufactured before October 1, 2006, and equipped 

with an event recorder that uses magnetic tape as its recording medium shall have 

the recorder removed from service on or before October 1, 2009 and replaced 

with an event recorder with a certified crashworthy event recorder memory 

module that meets the requirements of Appendix D of this Part and that records at 

least the same number of data elements as the recorder it replaces. 
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(3) A lead locomotive, a lead manned helper locomotive, and a controlling 

remotely distributed power locomotive, other than a DMU or MU locomotive, 

originally ordered on or after October 1, 2006 or placed in service on or after 

October 1, 2009, shall be equipped with an event recorder with a certified 

crashworthy event recorder memory module that meets the requirements of 

Appendix D of this part. The certified event recorder memory module shall be 

mounted for its maximum protection. (Although other mounting standards may 

meet this standard, an event recorder memory module mounted behind and below 

the top of the collision posts and above the platform level is deemed to be 

mounted “for its maximum protection.”) The event recorder shall record, and the 

certified crashworthy event recorder memory module shall retain, the following 

data elements: 

 (i) Train speed; 

 (ii) Selected direction of motion; 

 

 (iii) Time; 

 (iv) Distance; 

 (v) Throttle position; 

(vi) Applications and operations of the train automatic air brake, 

including 

emergency applications. The system shall record, or provide a means of 

determining, that a brake application or release resulted from manipulation 

of brake controls at the position normally occupied by the locomotive 

engineer. In the case of a brake application or release that is responsive to 

a command originating from or executed by an on-board computer (e.g., 

electronic braking system controller, locomotive electronic control system, 

or train control computer), the system shall record, or provide a means of 

determining, the involvement of any such computer; 

(vii) Applications and operations of the independent brake; 

(viii) Applications and operations of the dynamic brake, if so equipped; 

(ix) Cab signal aspect(s), if so equipped and in use; 

(x) End-of-train (EOT) device loss of communication front to rear and 

rear to front; 

(xi) Electronic controlled pneumatic braking (ECP) message (and loss 

of such message), if so equipped; 
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(xii) EOT armed, emergency brake command, emergency brake 

application; 

(xiii) Indication of EOT valve failure; 

(xiv) EOT brake pipe pressure (EOT and ECP devices); 

(xv) EOT marker light on/off; 

(xvi) EOT “low battery” status; 

(xvii) Position of on/off switch for headlights on lead locomotive; 

(xviii) Position of on/off switch for auxiliary lights on lead locomotive; 

(xix) Horn control handle activation; 

(xx) Locomotive number; 

(xxi) Locomotive automatic brake valve cut in; 

(xxii) Locomotive position in consist (lead or trail); 

(xxiii) Tractive effort; 

(xxiv) Cruise control on/off, if so equipped and in use; and 

(xxv) Safety-critical train control data routed to the locomotive engineer’s 

display with which the engineer is required to comply, specifically 

including text messages conveying mandatory directives, and maximum 

authorized speed. The format, content, and proposed duration for 

retention of such data shall be specified in the product safety plan 

submitted for the train control system under subpart H of part 236 of this 

chapter, subject to FRA approval under this paragraph. If it can be 

calibrated against other data required by this part, such train control data 

may, at the election of the railroad, be retained in a separate certified 

crashworthy memory module. 

(4) A DMU locomotive and an MU locomotive originally ordered on or after 

October 1, 2006 or placed in service on or after October 1, 2009, shall be 

equipped with an event recorder with a certified crashworthy event recorder 

memory module that meets the requirements of Appendix D of this Part. The 

certified event recorder memory module shall be mounted for its maximum 

protection. (Although other mounting standards may meet this standard, an event 

recorder memory module mounted behind the collision posts and above the 
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platform level is deemed to be mounted “for its maximum protection.”) The 

event recorder shall record, and the certified crashworthy event recorder memory 

module shall retain, the following data elements: 

(i) Train speed; 

(ii) Selected direction of motion; 

(iii) Time; 

(iv) Distance; 

(v) Throttle position; 

(vi) Applications and operations of the train automatic air brake, 

including emergency applications. The system shall record, or provide a 

means of determining, that a brake application or release resulted from 

manipulation of brake controls at the position normally occupied by the 

locomotive engineer. In the case of a brake application or release that is 

responsive to a command originating from or executed by an on-board 

computer (e.g., electronic braking system controller, locomotive electronic 

control system, or train control computer), the system shall record, or 

provide a means of determining, the involvement of any such computer; 

(vii) Applications and operations of the independent brake, if so 

equipped; 

(viii) Applications and operations of the dynamic brake, if so equipped; 

(ix) Cab signal aspect(s), if so equipped and in use; 

(x) Emergency brake application(s); 

(xii) Wheel slip/slide alarm activation (with a property-specific 

minimum duration); 

(xiii) Lead locomotive headlight activation switch on/off; 

(xiv) Lead locomotive auxiliary lights activation switch on/off; 

(xv) Horn control handle activation; 

 

(xvi) Locomotive number; 

(xvii) Locomotive position in consist (lead or trail); 

 
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(xviii) Tractive effort; 

(xix) Brakes apply summary train line; 

(xx) Brakes released summary train line; 

(xxi) Cruise control on/off, if so equipped and used; and 

(xxii) Safety-critical train control data routed to the locomotive 

engineer’s display with which the engineer is required to comply, 

specifically including text messages conveying mandatory directives, and 

maximum authorized speed. The format, content, and proposed duration 

for retention of such data shall be specified in the product safety plan 

submitted for the train control system under subpart H of part 236 of this 

chapter, subject to FRA approval under this paragraph. If it can be 

calibrated against other data required by this part, such train control data 

may, at the election of the railroad, be retained in a separate certified 

crashworthy memory module. 

(5) A locomotive equipped with an event recorder that is remanufactured, as 

defined in this part, on or after October 1, 2007, shall be equipped with an event 

recorder with a certified crashworthy event recorder memory module that meets 

the requirements of Appendix D to this Part and is capable of recording, at a 

minimum, the same data as the recorder that was on the locomotive before it was 

remanufactured. 

(6) An event recorder originally manufactured after January 1, 2010, that is 

installed on any locomotive identified in paragraph (b)(1) of this section shall be 

an event recorder with a certified crashworthy event recorder memory module 

that meets the requirements of Appendix D to this Part and that is capable of 

recording, at a minimum, the same data as the event recorder that was previously 

on the locomotive. 

(c) Removal from service. Notwithstanding the duty established in paragraph (a) of this 

section to equip certain locomotives with an in-service event recorder, a railroad may 

remove an event recorder from service and, if a railroad knows that an event recorder is 

not monitoring or recording required data, shall remove the event recorder from service. 

When a railroad removes an event recorder from service, a qualified person shall record 

the date that the device was removed from service on Form FRA F6180-49A, under the 

REMARKS section, unless the event recorder is designed to allow the locomotive to 

assume the lead position only if the recorder is properly functioning. 

(d) Response to defective equipment. Notwithstanding the duty established in paragraph 

(a) of this section to equip certain locomotives with an in-service event recorder, a 

locomotive on which the event recorder has been taken out of service as provided in 

paragraph (c) of this section may remain as the lead locomotive only until the next 
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calendar-day inspection. A locomotive with an inoperative event recorder is not deemed 

to be in improper condition, unsafe to operate, or a non-complying locomotive under §§ 

229.7 and 229.9, and, other than the requirements of Appendix D of this part, the 

inspection, maintenance, and testing of event recorders are limited to the requirements set 

forth in §§ 229.25(e) and 229.27(d). 

(e) Preserving accident data. If any locomotive equipped with an event recorder, or any 

other locomotive-mounted recording device or devices designed to record information 

concerning the functioning of a locomotive or train, is involved in an accident/incident 

that is required to be reported to FRA under part 225 of this chapter, the railroad that was 

using the locomotive at the time of the accident shall, to the extent possible, and to the 

extent consistent with the safety of life and property, preserve the data recorded by each 

such device for analysis by FRA. This preservation requirement permits the railroad to 

extract and analyze such data, provided the original downloaded data file, or an 

unanalyzed exact copy of it, shall be retained in secure custody and shall not be utilized 

for analysis or any other purpose except by direction of FRA or the National 

Transportation Safety Board. This preservation requirement shall expire one (1) year 

after the date of the accident unless FRA or the Board notifies the railroad in writing that 

the data are desired for analysis. 

(f) Relationship to other laws. Nothing in this section is intended to alter the legal 

authority of law enforcement officials investigating potential violation(s) of State 

criminal law(s), and nothing in this chapter is intended to alter in any way the priority of 

National Transportation Safety Board investigations under 49 U.S.C. 1131 and 1134, nor 

the authority of the Secretary of Transportation to investigate railroad accidents under 49 

U.S.C. 5121, 5122, 20107, 20111, 20112, 20505, 20702, 20703, and 20902. 

(g) Disabling event recorders. Except as provided in paragraph (c) of this section, any 

individual who willfully disables an event recorder is subject to civil penalty and to 

disqualification from performing safety-sensitive functions on a railroad as provided in § 

218.55 of this chapter, and any individual who tampers with or alters the data recorded by 

such a device is subject to a civil penalty as provided in appendix B of part 218 of this 

chapter and to disqualification from performing safety-sensitive functions on a railroad if 

found unfit for such duties under the procedures in part 209 of this chapter. 

Guidance

1. Requires replacement, by October 1, 2009, of each event recorder using magnetic 

tape as a storage medium with a certified crashworthy ERMM capable of recording at 

least the same data elements as the recorder it replaces. Any magnetic tape recorder 

replaced after October 1, 2005, must be replaced with a certified crashworthy event 

recorder memory module. 

2. Requires all new lead locomotives, lead manned helper locomotives, and controlling 

distributive power locomotives (ordered after October 1, 2006, or placed in service after 

October 1, 2009) to be equipped with a certified crashworthy ERMM capable of 
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recording up to 25 data elements for traditional locomotives and 22 data elements for MU 

and DMU locomotives. 

3. Requires all remanufactured locomotives after October 1, 2007, to be equipped with a 

certified crashworthy ERMM capable of recording at least the same data elements as the 

event recorder on that locomotive prior to remanufacture. 

4. Requires event recorders originally manufactured after January 1, 2010, and installed 

on a covered locomotive, to be equipped with a certified crashworthy ERMM. 

5. Contains specific performance criteria for determining the crashworthiness of an 

ERMM. These include criteria for fire, impact shock, static crush, fluid immersion, and 

hydrostatic pressure and contains testing sequence requirements. The criteria are based 

on existing crashworthiness standards of the IEEE, modified for the locomotive 

environment. 

6. Requires preservation of event recorder data for a period of 1 year for any locomotive 

involved in an accident or incident required to be reported to FRA under part 225. 

7. Provides relief from the periodic inspection requirements for microprocessor-based 

event recorders with self-monitoring features. Requires inspection of these types of event 

recorders annually. 

§ 229.137 Sanitation, general requirements. 

(a) Sanitation compartment. Except as provided in paragraph (b) of this section, all lead 

locomotives in use shall be equipped with a sanitation compartment. Each sanitation 

compartment shall be: 

 

(1) Adequately ventilated; 

 

(2) Equipped with a door that: 

 (i) Closes, and 

(ii) Possesses a modesty lock by October 4, 2003; 

 (3) Equipped with a toilet facility, as defined in this part; 

(4) Equipped with a washing system, as defined in this part, unless the railroad 

 otherwise provides the washing system to employees upon reporting for duty 

 or occupying the cab for duty, or where the locomotive is equipped with a 

 stationary sink that is located outside of the sanitation compartment; 

(5) Equipped with toilet paper in sufficient quantity to meet employee needs, 

unless the railroad otherwise provides toilet paper to employees upon reporting 
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for duty or occupying the cab for duty; and 

(6) Equipped with a trash receptacle, unless the railroad otherwise provides 

portable trash receptacles to employees upon reporting for duty or occupying the 

cab for duty. 

 (b) Exceptions. (1) Paragraph (a) of this section shall not apply to: 

(i) Locomotives engaged in commuter service or other short-haul 

passenger service and commuter work trains on which employees have 

ready access to railroad-provided sanitation facilities outside of the 

locomotive or elsewhere on the train, that meet otherwise applicable 

sanitation standards, at frequent intervals during the course of their work 

shift; 

(ii) Locomotives engaged in switching service on which employees have 

ready access to railroad-provided sanitation facilities outside of the 

locomotive, that meet otherwise applicable sanitation standards, at 

frequent intervals during the course of their work shift; 

(iii) Locomotives engaged in transfer service on which employees have 

ready access to railroad-provided sanitation facilities outside of the 

locomotive, that meet otherwise applicable sanitation standards, at 

frequent intervals during the course of their work shift; 

(iv) Locomotives of Class III railroads engaged in operations other than 

switching service or transfer service, which are not equipped with a 

sanitation compartment as of June 3, 2002. Where an unequipped 

locomotive of a Class III railroad is engaged in operations other than 

switching or transfer service, employees shall have ready access to 

railroad-provided sanitation facilities outside of the locomotive that meet 

otherwise applicable sanitation standards, at frequent intervals during the 

course of their work shift, or the railroad shall arrange for en route access 

to such facilities; 

(v) Locomotives of tourist, scenic, historic, or excursion railroad 

operations, which are otherwise covered by this part because they are not 

propelled by steam power and operate on the general railroad system of 

transportation, but on which employees have ready access to railroadprovided sanitation facilities outside of the locomotive, that meet 

otherwise applicable sanitation standards, at frequent intervals during the 

course of their work shift; and 

(vi) Except as provided in § 229.14 of this part, control cab locomotives 

designed for passenger occupancy and used in intercity push-pull service 

that are not equipped with sanitation facilities, where employees have 
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ready access to railroad-provided sanitation in other passenger cars on the 

train at frequent intervals during the course of their work shift. 

(2) Paragraph (a)(3) of this section shall not apply to: 

(i) Locomotives of a Class I railroad which, prior to June 3, 2002, were 

equipped with a toilet facility in which human waste falls via gravity to a 

holding tank where it is stored and periodically emptied, which does not 

conform to the definition of toilet facility set forth in this section. For 

these locomotives, the requirements of this section pertaining to the type 

of toilet facilities required shall be effective as these toilets become 

defective or are replaced with conforming units, whichever occurs first. 

All other requirements set forth in this section shall apply to these 

locomotives as of June 3, 2002; and 

(ii) With respect to the locomotives of a Class I railroad which, prior to 

June 3, 2002, were equipped with a sanitation system other than the units 

addressed by paragraph (b)(2)(i) of this section, that contains and removes 

human waste by a method that does not conform with the definition of 

toilet facility as set forth in this section, the requirements of this section 

pertaining to the type of toilet facilities shall apply on locomotives in use 

on July 1, 2003. However, the Class I railroad subject to this exception 

shall not deliver locomotives with such sanitation systems to other 

railroads for use, in the lead position, during the time between June 3, 

2002, and July 1, 2003. All other requirements set forth in this section 

shall apply to the locomotives of this Class I railroad as of June 3, 2002. 

(c) Defective, unsanitary toilet facility; prohibition in lead position. Except as provided in 

paragraphs (c)(1) through (5) of this section, if the railroad determines during the daily 

inspection required by § 229.21 that a locomotive toilet facility is defective or is 

unsanitary, or both, the railroad shall not use the locomotive in the lead position. The 

railroad may continue to use a lead locomotive with a toilet facility that is defective or 

unsanitary as of the daily inspection only where all of the following conditions are met: 

(1) The unsanitary or defective condition is discovered at a location where there 

are no other suitable locomotives available for use, i.e., where it is not possible to 

switch another locomotive into the lead position, or the location is not equipped to 

clean the sanitation compartment if unsanitary or repair the toilet facility if 

defective; 

(2) The locomotive, while non-compliant, did not pass through a location where it 

could have been cleaned if unsanitary, repaired if defective, or switched with 

another compliant locomotive, since its last daily inspection required by this part; 

(3) Upon reasonable request of a locomotive crewmember operating a locomotive 

with a defective or unsanitary toilet facility, the railroad arranges for access to a 
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toilet facility outside the locomotive that meets otherwise applicable sanitation 

standards; 

(4) If the sanitation compartment is unsanitary, the sanitation compartment door 

shall be closed and adequate ventilation shall be provided in the cab so that it is 

habitable; and 

(5) The locomotive shall not continue in service in the lead position beyond a 

location where the defective or unsanitary condition can be corrected or replaced 

with another compliant locomotive, or the next daily inspection required by this 

part, whichever occurs first. 

(d) Defective, unsanitary toilet facility; use in trailing position. If the railroad determines 

during the daily inspection required by § 229.21 that a locomotive toilet facility is 

defective or is unsanitary, or both, the railroad may use the locomotive in trailing 

position. If the railroad places the locomotive in trailing position, they shall not haul 

employees in the unit unless the sanitation compartment is made sanitary prior to 

occupancy. If the toilet facility is defective and the unit becomes occupied, the railroad 

shall clearly mark the defective toilet facility as unavailable for use. 

(e) Defective, sanitary toilet facility; use in switching, transfer service. If the railroad 

determines during the daily inspection required by § 229.21 that a locomotive toilet 

facility is defective, but sanitary, the railroad may use the locomotive in switching 

service, as set forth in paragraph (b)(1)(ii) of this section, or in transfer service, as set 

forth in paragraph (b)(1)(iii) of this section for a period not to exceed 10 days. In this 

instance, the railroad shall clearly mark the defective toilet facility as unavailable for use. 

After expiration of the 10-day period, the locomotive shall be repaired or used in the 

trailing position. 

(f) Lack of toilet paper, washing system, trash receptacle. If the railroad determines 

during the daily inspection required by § 229.21 that the lead locomotive is not equipped 

with toilet paper in sufficient quantity to meet employee needs, or a washing system as 

required by paragraph (a)(4) of this section, or a trash receptacle as required by paragraph 

(a)(6) of this section, the locomotive shall be equipped with these items prior to 

departure. 

(g) Inadequate ventilation. If the railroad determines during the daily inspection required 

by § 229.21 that the sanitation compartment of the lead locomotive in use is not 

adequately ventilated as required by paragraph (a)(1) of this section, the railroad shall 

repair the ventilation prior to departure, or place the locomotive in trailing position, in 

switching service as set forth in paragraph (b)(1)(ii) of this section, or in transfer service 

as set forth in paragraph (b)(1)(iii) of this section. 

(h) Door closure and modesty lock. If the railroad determines during the daily inspection 

required by § 229.21 that the sanitation compartment on the lead locomotive is not 

equipped with a door that closes, as required by paragraph (a)(2)(i) of this section, the 
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railroad shall repair the door prior to departure, or place the locomotive in trailing 

position, in switching service as set forth in paragraph (b)(1)(ii) of this section, or in 

transfer service as set forth in paragraph (b)(1)(iii) of this section. If the railroad 

determines during the daily inspection required by § 229.21 that the modesty lock 

required by paragraph (a)(2)(ii) of this section is defective, the modesty lock shall be 

repaired pursuant to the requirements of § 229.139(e). 

(i) Equipped units; retention and maintenance. Except where a railroad downgrades a 

locomotive to service in which it will never be occupied, where a locomotive is equipped 

with a toilet facility as of [the effective date of the final rule], the railroad shall retain and 

maintain the toilet facility in the locomotive consistent with the requirements of this part, 

including locomotives used in switching service pursuant to paragraph (b)(1)(ii) of this 

section, and in transfer service pursuant to paragraph (b)(1)(iii) of this section. 

(j) Newly manufactured units; in-cab facilities. All locomotives manufactured after June 

3, 2002, except switching units built exclusively for switching service and locomotives 

built exclusively for commuter service, shall be equipped with a sanitation compartment 

accessible to cab employees without exiting to the out-of-doors for use. No railroad may 

use a locomotive built after June 3, 2002, that does not comply with this subsection. 

(k) Potable water. The railroad shall utilize potable water where the washing system 

includes the use of water. 

§ 229.139 Sanitation, servicing requirements. 

(a) The sanitation compartment of each lead locomotive in use shall be sanitary. 

(b) All components required by § 229.137(a) for the lead locomotive in use shall be present 

consistent with the requirements of this part, and shall operate as intended such that: 

(1) All mechanical systems shall function; 

(2) Water shall be present in sufficient quantity to permit flushing; 

(3) For those systems that utilize chemicals for treatment, the chemical (chlorine 

or other comparable oxidizing agent) used to treat waste must be present; and 

(4) No blockage is present that prevents waste from evacuating the bowl. 

(c) The sanitation compartment of each occupied locomotive used in switching service pursuant 

to § 229.137(b)(1)(ii), in transfer service pursuant to § 229.137(b)(1)(iii), or in a trailing position 

when the locomotive is occupied, shall be sanitary. 

(d) Where the railroad uses a locomotive pursuant to § 229.137(e) in switching or transfer 

service with a defective toilet facility, such use shall not exceed 10 calendar days from the date 
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on which the defective toilet facility became defective. The date on which the toilet facility 

becomes defective shall be entered on the daily inspection report. 

(e) Where it is determined that the modesty lock required by § 229.137(a)(2) is defective, the 

railroad shall repair the modesty lock on or before the next 92-day inspection required by this 

part. 

 

Guidance

There are several types of locomotive cab toilet facilities in use today. Micophor, Envirovac 

Vacuum Systems (EVAC), and Motive Equipment, Inc. (MEI) are a few of the most common 

types. 

The Norfolk Southern Railway and Amtrak primarily use the EVAC systems. 

Microphor uses a two-tank system, the only one of its kind. Human waste is deposited in the 

tank directly below; when flushed, it is passed by way of piping into a chemical (chlorine) 

holding tank for biological break-down, and then passed out to a drip pipe to atmosphere (rightof-way). 

Other manufacturer’s toilets use only one tank. The same tank that waste is passed into is used 

as a holding tank. The flush simply opens a flapper and forces clean water to wash or rinse the 

bowl and then allows the waste to pass into the tank below where it is biologically (chemically) 

broken down. If the proper amount of chlorine is used, and the tank is not overfilled to capacity, 

it is retained until it is sucked out by the railroad maintenance person when it is time for service. 

The most common causes for locomotive toilet systems failing, regardless of the manufacturer, is 

the lack of maintenance by the railroads, vandalism, and paper towels and/or various other types 

of foreign matter being introduced into the toilet system. Toilet systems are only designed to 

break down human waste and common toilet paper. 

Surveys indicate that any kind of paper towel will clog and foul these toilet systems. By being 

too thick to be broken down by the chlorine, it clogs the system and makes the filtering system 

ineffective. 

The quality and/or lack of maintenance by the railroads greatly contribute to noncompliance 

problems. Individual railroads are responsible for maintenance schedules. The frequency of 

maintenance and servicing really depends on the use of the facility, the number of crewmembers, 

crew changes, and use by outside parties. Often, servicing personnel are guilty of using the 

wrong or improper chemicals to break down the bacteria in the toilet systems. Also, if an 

improper cleaning agent is used to clean the toilet, it can contaminate and render the toilet’s 

chemicals ineffective. 

The most common complaints are: 

1. Toilet compartment stinks/dirty 
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2. System toilet tank plugged 

3. Toilet does not flush 

4. Lack of or no water in holding tank 

5. Waste system pipe leaks 

6. Water tank leaks 

7. Strong chlorine odor in toilet compartment 

8. Low voltage ground from tank heating system 

9. Full or overflowing tanks (models with holding tanks) 

10. Insufficient chlorine in chlorinator 

11. Strong chlorine odor in cab (poor or no ventilation) 

12. Vent pipe or vent hole plugged 

13. Waste holding tank or fresh water holding tank frozen 

14. Broken or damaged chlorinator caps and seals 

15. Loose chlorine slugs on floor in toilet compartment 

16. Toilet does not flush 

17. Tampons and/or feminine napkins found in toilet bowls and cannot be broken down 

in chlorine. This is becoming more of a common problem since the rise of female 

employees throughout the railroad system. 

Section 229.137(c) prohibits a railroad from placing a locomotive with an unsanitary or defective 

toilet in the lead position. The railroad makes this determination at the time of the daily 

inspection required by § 229.21. In order for FRA take a violation of § 229.137(c), among other 

things, FRA must show that the railroad determined at the time of the daily inspection that the 

locomotive toilet facility was defective and/or unsanitary. Without that showing, FRA will not 

be able to sustain a violation. 

This also applies if FRA wants to take violations under § 229.137(d)–(h). For each of those 

sections, FRA must show that the railroad made the determination (e.g., lack of toilet paper, 

inadequate ventilation, or lack of a modesty lock, etc.) at the time of the daily inspection. 

As noted in the preamble to the Final Rule, en route failures that occur after the daily inspection 

impose no burden on the railroad until the next daily inspection is due. According to working 

group members involved in drafting the rule, the current railroad practice concerning en route 

toilet failures is to move defective toilets into the trailing position, where it is possible to do so. 

Please note, however, that the final rule does not require such a movement. 

Proper Ventilation 

Ventilation is a serious problem. Some of the problems found during a field survey are that the 

vent caps have been pulled off or removed and the vent pipe has been plugged with paper towels. 
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With the toilet in use and no ventilation, the odor will soon migrate into the cab and crew area of 

the locomotive. 

Some railroads simply cut a hole in the nose of the cab and place a vent over it, to avoid outside 

debris from entering the toilet compartment. This is the basic system using ambient air to 

circulate. It works best when the toilet compartment door is closed and the locomotive is in 

motion. However, some railroads have installed a positive pressure ventilation system. This is 

done by a pipe that runs from the toilet compartment through the cab wall and into the engine 

room exhaust fan compartment. This system vents even if the locomotive is standing still and 

the toilet compartment door open. Note: This system still works best with the toilet 

compartment door closed. Some locomotives will not vent while standing still. They only vent 

with the locomotive in motion, and when the toilet compartment door is kept closed. This is 

commonly known as negative air flow. However, this is not an exception nor a violation, if the 

door is open and the locomotive is standing still. If the toilet is operating properly and the door 

is closed with the locomotive standing still, the cab odor should be minimal and diminish when 

the locomotive is in motion. There are no specifications as to how a locomotive toilet facility 

can be or has to be vented. The important thing is that it works. All toilet compartments, 

regardless of type of locomotive or venting system, work best with the toilet compartment door 

closed. 

Toilet compartment door gaskets (seals) make a difference in ventilation and should be replaced 

when needed. Although the regulation does not specifically address the door seals or gasket, 

inspectors should note a defective door seal or gasket and inform the railroad supervisor in 

charge of locomotive repairs and/or service that the defective condition could lead to an odor 

problem, which could become a compliance issue. 

Toilet Facility Lighting

The sanitation regulations do not specifically address lighting for the toilet compartment. 

However, because the toilet facility is considered a compartment of the locomotive, the 

provisions of § 229.127(b) would apply. Therefore, if the lighting is inadequate, missing, or 

inoperative, then it should be considered as a defect. Surveys have indicated that lighting 

problems are attributed to either the use of light bulbs with improper wattage or burned out light 

bulbs. This can also be considered a tripping hazard if the compartment is dark enough or even 

near black (zero visibility). In the case of many older locomotives, appurtenances have been 

installed or retrofitted in the nose of the locomotive in such a manner as to impose an obstruction 

in the way of the toilet, and in some cases can cause accident or injury to the person using the 

facility. 

Modesty Locks

Modesty lock means a latch that can be operated in the normal manner only from within the 

sanitary compartment that is designed to prevent entry of another person when the sanitary 

compartment is in use. A modesty lock may be designed to allow deliberate forced entry in the 

event of an emergency. 
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Important Note: The modesty lock does not have to be able to be opened from the outside in an 

emergency. Most modesty locks currently in use consist of a secondary latch, and are generally 

made of plastic and can easily be broken with moderate force. If the secondary latch is being 

used as a modesty lock and is broken, then this should be considered a defective modesty lock 

and handled in accordance with § 229.139 (e). 

Acceptable Forms of Sanitation (Personal Hygiene) 

There should also be a sufficient quantity of fresh water, either for drinking or for washing or 

rinsing hands after using the toilet facility. 

There are many types of acceptable forms of cleaning and washing solutions for crew members 

to use for personal hygiene. The most common is crew packs. This package contains waterless 

hand cleaner, paper towels, a small quantity of toilet paper and a trash bag. These are usually 

available either when the crew reports for duty or placed in the cab by railroad service 

employees. Some locomotives may also be equipped with sinks for washing hands. If this is the 

case, then an ample amount of water must be available for washing and rinsing hands. However, 

sinks are not mandatory, and even if a sink is in place, it may not be used if crew packs are 

available. 

Subpart D – Design Requirements 

§ 229.141 Body structure, MU locomotives. 

Guidance 

Although this Subpart is not expected to be used by the field inspectors during routine inspection 

activity, it must be considered when conducting accident investigations, especially when there 

has been a head-on or rear end collision. Also, event recorder preservation requirements must be 

observed. 
9 - 1

Chapter 9 

Steam Locomotive Inspection and Maintenance Standards, Part 230

Introduction

The first Federal statute addressing steam locomotives was the Ash Pan Act passed by Congress 

on May 30, 1908. The act described how the ash pans were to be attached to the steam boiler, 

that they were to be maintained in a safe suitable condition for service, and that all operating 

mechanisms of the ash pans shall be arranged so that they may be safely operated. Prior to the 

Act, a person had to empty the ash pan by crawling under the locomotive, and if the locomotive 

moved he was either killed or injured. The Ash Pan Act was repealed by Congress as part of the, 

“Federal Railroad Safety Authorization Act of 1982” but ash pans are still under Federal 

regulations and referenced in 49 CFR § 230.69, Ash Pans, of the Steam Locomotive Inspection 

and Maintenance Standards. 

On February 17, 1911, Congress passed the Locomotive Inspection Act, bringing all locomotive 

steam boilers under Federal auspices and laying out the structure of the Bureau of Locomotive 

Inspection with its attendant administrative and field force personnel of 50 locomotive inspectors 

and their specific duties. The Bureau was made a part of the Interstate Commerce Commission. 

The Act held the district inspector responsible for the locomotives housed in his district. On 

March 4, 1915, the Act was amended to include not only the steam boiler but the entire 

locomotive and its appurtenances. The steam locomotive regulations are codified under 

49 CFR Part 230 Sections 1–199. 

The regulations pertaining to steam locomotives were last published in November 1999, under 

49 CFR Part 230, when FRA issued a Final Rule on Steam Locomotive Inspection and 

Maintenance Standards. The rule went into effect on January 18, 2000, however, 

implementation of the new rule was designed to allow the steam owner/operators to phase in the 

new requirements over a period of time. The new rule was revised to consider the operating 

realities of today’s steam locomotive operations which consist primarily of tourist and excursion 

service. A new inspection scheme was developed subjecting steam locomotives to periodic 

inspections and tests based on “service days” rather than “calendar days.” The new regulation 

required all owner/operators of steam locomotives to conduct an engineering survey of the 

boiler, which must reflect the current condition of the boiler at the time the survey is made. 

Results of the survey are reported on boiler specification card, FRA Form 4. 

A steam locomotive boiler is an external combustion engine in which burning fuel converts 

water into steam in a horizontal boiler. The steam is directed into that portion of the locomotive 

called a steam engine where the expansion properties of the steam are allowed to act on both 

sides of a driver piston to rotate the driving wheels. Most of the steam locomotives in service 

today have two steam engines, but several railroads have locomotives which have four steam 

engines. The piston is connected to the drive wheels through a cross head arrangement, main 

rods and side rods. Control of the speed of the locomotive is accomplished through the throttle 

mechanism as manipulated by the engineer in the cab. When steam locomotives were the 

predominant form of tractive power, there were approximately 75,000 in service. The steam 
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locomotive was a labor intensive piece of machinery requiring constant attention and hard work 

to maintain them in a safe and suitable condition for service. 

The most critical area of the steam locomotive is the boiler. Keep in mind that 1 cubic inch of 

water is converted to 1,600 cubic inches of steam (at atmospheric pressure); and at a pressure of 

150 psi, the temperature of saturated steam is 366 degrees. This pressure is attempting to rupture 

the boiler; and it is the design, maintenance and inspection required by FRA regulations, and 

good maintenance practices by the owners/operators of steam locomotives, which prevents this 

from occurring. When steam boilers do rupture, it is of a cataclysmic nature which can move the 

mass of the boiler off the rail, and in many cases kills the engineer and fireman. These facts are 

presented so that you are aware that the steam boiler is a pressure vessel which can be extremely 

dangerous if not properly inspected and maintained. 

There are over 100 active steam locomotives operating in the United States under FRA’s 

jurisdiction. The monitoring of the steam locomotives is the responsibility of the FRA inspector 

that has attended Safety Improvement and Development Division (SIDD) training addressing 

Part 230. The FRA inspector should endeavor to inspect each steam locomotive under his/her 

jurisdiction no less than twice each year, once under hydrostatic pressure, and once when under 

working steam pressure. Excluding steam locomotives that do not permit access, FRA policy 

requires inspectors to perform an interior inspection of the boiler proper (steam space), firebox,

and smokebox once each year, when possible, and at every 1,472 service day inspection. The 

FRA inspector is also responsible for maintaining all records and associated reports for each 

steam locomotive under his/her charge. Each railroad and owner of a steam locomotive, which 

falls under these Federal regulations, should forward all required reports to the Regional office in 

which the steam locomotive is housed. The Washington office will not be responsible for 

maintaining regional steam locomotive files. 

FRA no longer considers requests to the Regional Administrators for flue removal extensions. 

Locomotives are now required to receive a 1,472 service day inspection (49 CFR § 230.17), 

which includes the boiler survey and new specification card. Any waiver from these 

requirements would be processed under Part 211 and the FRA Railroad Safety Board. 

All waivers under the Locomotive Boiler Inspection Act, previously issued, shall lapse on the 

date the locomotive comes under new requirements, unless a copy of the grant of waiver is filed 

for reassessment with FRA’s Office of Railroad Safety in Washington, DC, prior to that date. 

FRA will review the waiver and notify the applicant whether the waiver has been continued. 

In regards to the actual boiler inspection, asbestos may be observed at certain points of a steam 

locomotive used as insulation to prevent thermal loss. As long as the asbestos is not friable (i.e., 

loose and flaking with fibers floating in the air, which could be inhaled into the lungs, and/or is 

completely shielded to prevent contact), it is not considered to be hazardous. If the asbestos is 

friable, the inspector need not expose himself/herself to any danger, but shall inform the railroad 

or owner of the locomotive that the asbestos must be properly removed or completely sealed and 

isolated from contact before the requested inspection can be performed. Asbestos fibers are 

known to be carcinogenic and if carried into the lungs can cause cancer or asbestoses. 
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Guidance 

FRA’s SIDD developed and provided training to FRA MP&E inspectors on design and 

inspection of steam locomotives and the requirements of the Steam Locomotive Inspection and 

Maintenance Standards. Those inspectors who successfully completed the SIDD training are 

deemed qualified to inspect steam locomotives for compliance with these regulations. 

This correspondence is directly related to those MP&E Inspectors who have successfully 

completed the Steam Locomotive OJT Standards without formally attending classroom 

training. It has been determined that holding their qualification in order to inspect steam 

locomotive rolling equipment for compliance under 49 CFR Part 230 – Steam Locomotive 

Inspection and Maintenance Standards before formally attending classroom training is not 

in the best interest of safety. 

Effective immediately, MP&E Inspectors who have successfully completed Steam Locomotive 

OJT may conduct independent inspections for compliance with Part 230. Be aware that the 

Office of Safety continues to encourage using two qualified Steam Locomotive inspectors when 

feasible, especially when conducting interior inspections. 

Further guidance dictates that any inspector having questions related to steam locomotive 

inspections covered under 49 CFR Part 230 should immediately contact their specialist or 

headquarters specialist for guidance. 

The National Boiler Inspection Code (NBIC) (Supplement 1, Parts 2 and 3) contains specific 

rules and special requirements for inspection, repairs, alterations, and storage of steam 

locomotive boilers. This is a National Standard that railroads, owners, and operators may use 

during inspection and repair. Inspectors should have a copy of the NBIC with them when 

conducting steam locomotive inspections, and be familiar with its requirements. Note: The 

“historical boiler” sections of the NBIC do not apply to steam locomotive boilers under the 

jurisdiction of the FRA. 

Regulation 49 CFR Part 230

Subpart A – General

§ 230.1 Purpose and scope. 

§ 230.2 Applicability.

§ 230.3 Implementation.

Guidance 

Section (b) Interim flue removal extensions. 
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FRA no longer considers requests for flue removal extensions under the provisions of § 230.10 

of the regulations in effect prior to January 18, 2000. 

Section (c) Petition for special consideration. Locomotives that have either fully or partially 

satisfied the requirements of 49 CFR § 230.17 after September 25, 1995, and before January 18, 

2000, could request special consideration to be grandfathered under the new requirements, 

provided the locomotive is in full compliance with 49 CFR § 230.17 by the time the petition is 

actually filed. The time period to file these petitions expired January 18, 2001, but FRA has 

considered and the Safety Board has granted waivers to extend the filing date; however, the 

request must be accompanied by all relevant documentation to be considered (including an FRA 

Form No. 4, and all records that demonstrate the number of days the locomotive has been in 

service). 

§ 230.4 Penalties. 

§ 230.5 Preemptive effect. 

§ 230.6 Waivers

Guidance 

A person, or operator, may petition for a waiver of any Part 230 requirement. Each petition for 

waiver must be filed according to Part 211 of this chapter. All steam locomotive waivers, 

granted prior to January 18, 2000, lapsed on that date; which is the effective date of the current 

rule. A common practice under the previous Part 230, referred to as a “Flue Removal 

Extension,” is no longer available. Any request for variance of the regulation must be processed 

as stated above. 

§ 230.7 Responsibility for compliance.

Guidance 

This section states that the locomotive owner and/or operator is directly responsible for ensuring 

that all requirements of the Steam Locomotive Inspection and Maintenance Standards are 

satisfied and that a locomotive is safe and suitable for service. This part does not relieve the 

railroad, over which the steam locomotive is operating, from its responsibility that the steam 

locomotive or tender are in proper condition and safe to operate. 

§ 230.8 Definitions.

Guidance 

Alteration. Any change to the boiler which affects its pressure retention capability. Rating 

changes are considered alterations. An alteration could lower or raise the pressure vessels’ 

ability to retain pressure. 
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Renewal. Replacement in kind with a newly manufactured or remanufactured (restored to 

original tolerances) component. Materials shall be suitable for the service intended. A 

replacement in kind would be considered a repair. 

§ 230.12 Movement of non-complying steam locomotives.

Guidance

This section dealing with movement of a noncomplying steam locomotive is similar to the 

requirements for movement of a defective locomotive found in 49 CFR § 229.9. 

Section (a): When a noncomplying condition under Part 230 is found by either the railroad’s 

inspector or an MP&E Inspector, except as provided in paragraphs (b), the railroad may only 

move the steam locomotive as a lite locomotive or dead locomotive under whatever conditions 

that the qualified person and the railroad deem suitable for a safe move (except as provided in 

paragraphs (b)). The steam locomotive may be moved to any location the railroad designates to 

have it brought into compliance. If the FRA Inspector believes that the movement of the 

locomotive by the railroad under this section constitutes an immediately unsafe situation, such as 

a possible derailment, a Special Notice For Repairs (FRA Form F6180.8) may be issued to 

effectively remove the locomotive from service. In addition to describing the immediate unsafe 

condition, the inspector must also note that the movement restrictions or lack of (i.e., speed, 

distance, etc.), as proposed by the railroad, would create an additional unsafe problem. The 

inspector should never dictate to a railroad the conditions for the movement of any 

noncomplying locomotive, unless the condition is so deplorable that movement at any speed 

would create an unsafe condition. In either case, the inspector should consult with regional 

management prior to making any decision. Any restrictions are the railroad’s responsibility. 

Section (b) requires that a qualified person determine (i) that it is safe to move the locomotive, 

and (ii) the maximum speed and other restrictions necessary for safely conducting the movement. 

Difficulty in the interpretation and enforcement of § 230.12 arises as this section does not 

provide guidance with respect to the criteria used to “qualify” a person to make the 

determination required above. Decisions to continue the use of a noncomplying locomotive, in 

some cases, are being made by persons not qualified to make these decisions. A person qualified 

to perform a daily inspection may not necessarily possess the qualifications to make the 

determination that it is safe to move a defective locomotive. 

The qualified person must have demonstrated to the owner/operator at a minimum, the 

knowledge and ability to inspect steam locomotives and provide recommendations regarding the 

criteria listed in Section (b). This does not imply that the qualified person must possess intimate 

knowledge of and experience with all of the components and functions of a steam locomotive. 

When investigating an issue involving enforcement of 49 CFR § 230.12, inspectors must 

carefully examine the qualifications of the individual who made the safety recommendations to 

determine if the owner/operator acted in compliance with the regulations. 
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Section (d) allows for the continued use of a steam locomotive that develops an en route 

noncomplying condition until the earlier of: (1) the next calendar day inspection, or (2) the 

nearest forward point where the repairs necessary to bring it into compliance can be made. Use 

of a locomotive under this provision is permitted only if the requirements of 49 CFR § 230.12(a) 

are fully met, which means a “noncomplying tag” that is properly filled out must be in the cab of 

the noncomplying steam locomotive. 

Where an MP&E Inspector has knowledge that a railroad permits steam locomotives, which 

develop en route noncomplying conditions, to continue in service past mechanical facilities 

where repairs can be made, the inspector should investigate to determine that the requirements of 

Section (a) are being complied with. If the inspector is made aware that a noncomplying 

locomotive was moved beyond a forward repair location that has previously demonstrated the 

ability to effect repairs of the noncomplying condition, the inspector must ensure that the subject 

locomotive would no longer be used as a propelling or lead locomotive. 

Section 230.12 allows a railroad to move a noncomplying steam locomotive as a lite or dead 

locomotive to a more distant repair point of its choice, provided it meets all other requirements 

of 49 CFR § 230.12, and such action does not endanger the safety of employees, locomotives, or 

train. 

Section 230.12 only permits the movement of a noncomplying locomotive with a Part 230 

defect. Nothing in 49 CFR § 230.12 authorizes the movement of a steam locomotive with power 

brake or safety appliance defects. Such locomotives can only be moved under provisions of 49 

U.S.C. § 20303 of the Act and/or the Power Brake Regulations. (MP&E 98-50) It is the 

responsibility of the railroad to ensure that any locomotive moved with a noncomplying defect is 

in accordance with the applicable law. If there is any doubt, the railroad should contact the FRA. 

The move may require the railroad to submit for one-time movement authority. (See Chapter 2). 

§ 230.13 Daily inspection. 

Guidance 

Section 230.13(a) is similar to the requirements found in the Locomotive Safety Standards 

§ 229.21, Daily inspection, for each day that the steam locomotive is in service. The purpose of 

the daily inspection is to ascertain that the locomotive is safe to operate in the service for which 

it is used, and is in total compliance with Part 230 prior to being placed in service. It is a visual 

walk-around inspection of the locomotive that provides an opportunity, every day the locomotive 

is used, to find and correct incipient problems before they lead to an accident or safety incident. 

An effective locomotive calendar day inspection requires that the individual performing the 

inspection be alert for telltale signs of any condition or defect that is a potential hazard. 

Reference to Appendices A (Inspection Requirements) and B (Diagrams and Drawings) 

reference items and should not be considered all encompassing. They are only provided as an 

example and do not relieve the owner/operator from performing a proper inspection. 
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After a daily inspection is performed, the steam locomotive should be free of any noncomplying 

conditions before it is offered for service. The locomotive cannot legally be used until all 

Federal defects are corrected. 

If the inspector continues to find recurrent defects or a pattern of noncomplying conditions at a 

particular location, the inspector should monitor the performance and the results of the daily 

inspections, as well as question the individuals performing the inspections, to ascertain if the 

individuals have the knowledge and ability to perform such inspections. 

If daily inspection reports reflect noncomplying conditions on a steam locomotive and the 

inspector finds the conditions were not corrected by the railroad and that the locomotive 

continues to be used, violations should be submitted. Such violations should be accompanied by 

all the documentation available, with a complete explanation regarding the railroad operation at 

the location. 

Failure to complete or produce a record or report (in and of itself) is not sufficient evidence to 

establish that a railroad failed to perform an inspection. It is a “records” violation, unless other 

evidence (i.e., witness statement, interviews, event recorder downloads, visual observation, etc.) 

is obtained to establish the failure to conduct the inspection. If the only evidence available 

merely establishes a failure of a railroad to produce a required inspection report, then the 

appropriate section to cite for civil penalty is § 230.13(c), for a report not properly executed or 

retained. Use the “lack of a record and/or report” to support the other evidence obtained to 

establish a “failure to perform an inspection” violation. 

Section (a): A daily inspection is required by this section for each day a locomotive is in use. A 

written report and record are required when the inspection is performed, and documented on 

FRA Form No. 2. The inspection can be conducted at any time during the calendar day. It can 

be done just before midnight or just after midnight. 

Section (b): Pre-departure inspection requires at the beginning of each day the steam locomotive 

is used, that an individual competent to do so shall inspect the steam locomotive and its tender 

and appurtenances to ensure that they are safe and suitable for service, paying special attention to 

the following items: (1) water glasses and gauge cocks; (2) boiler feedwater delivery systems, 

such as injectors and feedwater pumps; and (3) air compressors and governors, and the air brake 

system. While the daily inspection can be performed at the operator’s discretion, the items listed 

in section (b) must be inspected at the beginning of each day. 

§ 230.14 Thirty-one (31) service day inspection.

Guidance 

Section (a) The 31 service day inspection must be performed no less then each time the steam 

locomotive accrues 31 service days. The reference to Appendix A to 49 CFR Part 230, 

Inspection Requirements, is a tool and should not be considered all encompassing. The lists are 

only provided as an example and do not relieve the owner/operator from performing a proper 

inspection. 
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Operators are required to maintain a list of all service days accrued by a locomotive. These lists 

must be provided to FRA upon request so that service days may be verified. A service day is 

accrued each day the locomotive boiler has steam pressure above atmospheric pressure, with fire 

in the firebox; in the case of a fireless steam locomotive, any calendar day that the boiler has 

steam pressure above atmospheric pressure. 

Section (b) allows FRA to request to be present during the 31 service day inspection. Once an 

agreeable date is reached, the railroad should plan to perform the required tests, and may do so 

even if FRA is unable to be there. If FRA feels that a particular operator is not performing all 

required tests or inspections, this is a way to verify. 

Section (c) requires that the operator, within 10 days of the 31 day inspection, file a copy of FRA 

Form No. 1, and provide a copy to FRA’s regional office where the locomotive is normally 

maintained. A sample of FRA Form No. 1 is provided in Appendix C to 49 CFR Part 230. 

§ 230.15 Ninety-two (92) service day inspection. 

Guidance 

The 92 service day inspection is performed at the third 31-service day inspection with additional 

requirements. The record retention and forwarding requirements remain the same as the31 

service day inspection requirements. 

§ 230.16 Annual inspection.

Guidance

(a) General. Annual inspection requirements are calendar driven not service day, even if a 

steam locomotive has only had 1 service day over the previous 368 service days. it would still 

require an annual inspection. The annual inspection includes all requirements of the daily 

inspection, and the 31 and 92 service day inspections found in Appendix A of the rule. At each 

fifth annual inspection, a flexible staybolt and cap inspection is required in accordance with 49 

CFR § 230.41. 

(b) FRA notification. The FRA Regional Administrators shall be provided written notice at 

least 1 month prior to an annual inspection and shall be afforded an opportunity to be present. If 

the Regional Administrator, or their representative, is unable to make the agreed upon date and a 

new date cannot be agreed to, the inspection may be performed on the previously scheduled date. 

(c) Filing inspection reports. Section (c) requires that the operator, within 10 days of the 

annual day inspection, file a copy of FRA Form No. 3, and provide a copy to FRA’s regional 

office where the locomotive is normally maintained. A sample of FRA Form No. 3 is provided 

in Appendix C of the rule. 

§ 230.17 One thousand four hundred seventy-two (1,472) service day inspection. 
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Guidance 

(a) General. The 1,472 service day inspection includes all inspection requirements found in 

Appendix A of the rule for daily, 31 service day, 92 service day, annual, 5th annual, and 1,472 

service day inspections. The 1,472 service day or 15-year timeframe begins when the 

locomotive is placed in service or 1 year from the day the first tube is reinstalled in the boiler, 

whichever occurs first. 

The 1,472 service day inspection requires that all tubes be removed from the locomotive so that 

the interior of the boiler can be thoroughly cleaned and inspected. Section 230.31(b) allows not 

removing the superheater flues if they don’t interfere with the interior inspection and if NDE 

testing of the flues shows that they are safe and suitable. The boiler thickness is verified and 

FRA Form No. 4 is recalculated. 

Section (b) requires that the operator, within 30 days of completing the 1,472 service day 

inspection, file a copy of FRA Form No. 4, and provide a copy to FRA’s regional office where 

the locomotive is normally maintained. A sample of FRA Form No. 4 is provided in Appendix 

C of the rule. There is no requirement for the owner/operator to provide supporting 

documentation of boiler survey and measurements used to fill out FRA Form No. 4 and develop 

the calculations. FRA inspectors, if available, should request the supporting documentation and 

provide the information to the MP&E Division at Headquarters, along with the form for review. 

Recordkeeping Requirements

§ 230.18 Service days. 

Guidance 

(a) Service day record. The steam locomotive owner and/or operator shall maintain and make 

available to FRA, upon request, a current copy of the service day record that contains the number 

of service days the steam locomotive has accrued since the last 31, 92, annual, and 1,472 service 

day inspections. A service day is accrued each day the locomotive boiler has steam pressure 

above atmospheric pressure, with fire in the firebox; in the case of a fireless steam locomotive, 

any calendar day that the boiler has steam pressure above atmospheric pressure. 

(b) Service day report. A service day report, FRA Form No. 5, must be submitted January 

31with the Regional Administrator accounting for the days the steam locomotive was in service 

from January 1 through December 31st of the preceding year, even if the locomotive had no 

service days. 

(c) Retirement where no service day reports filed. If no report is filed, the steam locomotive 

may be considered retired by FRA, and the locomotive owner/operator may have to complete all 

1,472 service day inspection items to return the steam locomotive to service. 

§ 230.19 Posting of FRA Form No. 1 and FRA Form No. 3.
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Guidance 

FRA Form Nos. 1 and 3 must be posted under a transparent cover in the cab of an in-service 

steam locomotive. FRA Form No. 1 will not be required for the first 31 service days following 

an annual inspection and the posting of an FRA Form No. 3. (See Appendix C of this rule.) 

§ 230.20 Alteration and repair report for steam locomotive boilers.

Guidance 

(a) Alteration or Repair reports (FRA Form No. 19), detailing the changes to the locomotive, 

must be filed with the FRA Regional Administrator within 30 days from the date the work was 

completed, and attached to and maintained with FRA Form No. 4 until such time as a new FRA 

Form No. 4 (reflecting the alteration) is submitted to the Regional Administrator. Alteration 

reports shall be filed and maintained for the life of the boiler. (See Appendix C of this rule.) 

FRA inspectors should be familiar with the boilers in their territory and monitor repairs to ensure 

that Alteration and Repair reports are submitted when work of this type is performed. 

Alterations and repairs are frequently performed during off-season nonoperating periods, and 

inspectors should make an effort to perform occasional spot checks on locomotives in their 

territory during those periods. 

§ 230.21 Steam locomotive number change. 

Subpart B-Boilers and Appurtenances

§ 230.23 Responsibility for general construction and safe working pressure.

Guidance 

The steam locomotive owner and operator are responsible for the general design and 

construction of the steam locomotive boilers under their control. 

Allowable Stress

§ 230.24 Maximum allowable stress.

Guidance 

The maximum allowable stress value on any component of a steam locomotive boiler shall not 

exceed 1⁄4 of the ultimate tensile strength of its material. All steam boilers in service must be 

designed and built to have a safety factor of at least 4; that is, it must be able to withstand a 

pressure of at least 4-times the normal working steam pressure 

§ 230.27 Maximum shearing strength of rivets.

Guidance 
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When the rule was published in November 1999, there was a requirement to calculate the 

maximum shearing strength of rivets, but there was no place to record the figure on FRA Form 

No. 4. On July 11, 2005, FRA issued a correction to the rule which requires that the maximum 

shearing strength of rivets calculation be recorded on FRA Form No. 4. 

§ 230.28 Higher shearing strength of rivets.

Guidance 

A higher shearing strength may be used for rivets when it can be shown through testing that the 

rivet material used is of such quality as to justify a higher allowable shearing strength. 

Inspection and Repair 

§ 230.29 Inspection and repair. 

Guidance 

The term “accepted industry standards” is used in several places throughout the regulation, and 

refers to established repair practices used by the industry over many years. Each inspector 

assigned to steam locomotive inspection was provided a CD during their SIDD training that 

contains a large number of these standards. Accepted industry standards are generally 

considered less stringent than National Standards. Inspectors should note whether the regulation 

requires a National Standard or established repair practice for a specific repair, and verify that 

the railroad is meeting the correct requirement. 

Guidance 

When the regulation addresses an accepted National Standard for boiler repairs, it is referring to 

the National Board Inspection Code (NBIC), The regulation does not require that the person be 

an NBIC stamp holder, only that the repair procedures follow NBIC methodology.

§ 230.30 Lap-joint seam boilers.

Guidance 

Upon inspection of a lap-joint, pay close attention to the edges of the seams for grooving or 

cracking. If a visual indication is observed, request that the locomotive owner/operator use a 

nondestructive test to verify the finding. 

§ 230.31 Flues to be removed.

(a) Inspection of the boiler interior. 

Guidance 
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The purpose of the removal of flues is to inspect the entire interior of the boiler and its bracing, 

not the flues; although the flues should be inspected while removed. 

(b) NDE testing. 

Guidance 

The rule allows that boilers be left in place, if they can be thoroughly cleaned and inspected 

without removing the superheater flues. The FRA Inspector may require their removal for cause. 

If left in place, the superheaters must be NDE tested. 

§ 230.32 Time and Method of Inspection. 

Guidance 

(a) Time of inspection. 

(b) Method of inspection. 

(1) Entire boiler. The 1,472 day inspection is the most comprehensive inspection performed on 

the boiler, and inspectors should closely monitor the railroads’ inspection procedure, and take 

this opportunity to personally inspect both the interior and exterior for the conditions described 

in this section. 

(2) Boiler interior. FRA inspectors entering the boiler should consider the following: 

Steam boilers are recognized as confined spaces. As such the hazards they may contain must be 

evaluated before entry to ensure that persons entering them will be able to work safely. FRA has 

a policy in place that defines the circumstances under which FRA employees can enter confined 

spaces–such as steam boilers–safely. It is not expected that very many, if any, steam boilers will 

present hazards severe enough to prohibit entry. However, the procedures that are part of the 

policy must be followed to ensure that it is safe to enter a boiler. 

The primary stricture in the policy is the following statement: 

“No person shall enter, or order a subordinate to enter any permit-required confined 

space. Entry into other classes of confined spaces shall be done in accordance with the 

regulatory requirements, and this policy and procedure.” 

The key words here are “permit-required confined space.” MP&E inspectors following the 

procedures will be able to determine whether or not a boiler is “permit-required” and, if not, 

make the entry safely. A brief review of some of the key definitions and procedures begins with 

the definition of confined space: 

Confined Space means a space that has all three of the following characteristics: 
Motive Power and Equipment Compliance Manual 

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 It is large enough and so configured that an employee can bodily enter and perform 

assigned work. 

 It has limited or restricted means for entry or exit (for example; tanks, vessels, silos, 

storage bins, hoppers, vaults, pits, etc.). 

 It is not designed for continuous human occupancy. 

An “Entry” into a confined space is considered to be “breaking the plane” of the opening into 

the confined space in such a manner that you are exposed to the hazards. 

Confined spaces can be classified based on the nature and severity of the safety and health 

hazards they contain. Permit-required spaces contain the most severe hazards, and can’t be 

controlled or eliminated. Alternate-procedure spaces only have atmospheric hazards–“bad 

air”–that can be controlled by ventilation. Non-permit spaces do not contain, but have the 

potential to contain, any hazard capable of causing death or serious physical harm. 

Keep in mind that confined spaces that can be entered without restriction MUST be evaluated 

and found to be free of recognized serious safety hazards (those that can cause serious illness, 

injury or death), free of atmospheric hazards, and having sufficient oxygen to support the life of 

the inspector for the time required to be in the space. 

FRA procedures use a “Confined Space Evaluation Checklist,” which provides a standard format 

for the evaluation process. It is to be used by FRA personnel to make the evaluations necessary 

for deciding whether or not to enter the space. Each Region has a 4 gas atmosphere test 

instrument for determining the levels of oxygen, carbon monoxide, hydrogen sulfide, and 

flammable gas/vapor in an atmosphere. Your specialist or Regional Collateral Duty Safety 

Officer will be able to facilitate getting the instrument and a supply of the checklists. 

FRA inspectors shall strictly follow the guidelines below when entering a confined space: 

1. Comply with the confined space entry requirements related OSHA’s standards. 

2. Two inspectors shall participate consistent with FRA policy. 

3. The more experienced (formally certified) inspector takes the lead on all inspections related to 

Part 230. 

4. This guidance does not excuse the trainee from completing all of the task(s) outlined in the 

OJT Standards. It is understood that a task e.g., Duty 5: Identify Steam Locomotive 1472 

Service Day Inspection Requirements; could take longer to complete due to the operating 

constraints of the railroad. 

(3) Boiler exterior. A thorough inspection shall be made of the entire exterior of the boiler while 

under hydrostatic pressure. 

§ 230.33 Welded repairs and alterations.
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Guidance

When the regulation addresses an accepted National Standard for boiler repairs, it is referring to 

NBIC. The regulation does not require that the person be an NBIC- stamp holder, only that the 

repair procedures follow NBIC methodology. If a railroad proposes to make a welded flush 

patch repair/alteration, in addition to the railroad submitting their written request to the FRA 

Regional Administrator, the railroad must provide a copy of the entire package to MP&E 

Division headquarters, for review prior to granting approval. 

§ 230.34 Riveted repairs and alterations.

Guidance 

When the regulation addressees an accepted National Standard for boiler repairs, it is referring to 

NBIC. The regulation does not require that the person be an NBIC stamp holder, only that the 

repair procedures follow NBIC methodology. If a railroad proposes to make a riveted alteration 

to an un-stayed portion of a boiler, in addition to the railroad submitting their written request to 

the FRA Regional Administrator, the railroad must provide a copy of the entire package to 

MP&E Division headquarters, for review prior to granting approval. 

Pressure Testing of Boilers

§ 230.35 Pressure testing.

Guidance 

The temperature of the steam locomotive boiler shall be raised to at least 70 degrees Fahrenheit 

any time hydrostatic pressure is applied to the boiler. This is a new requirement. It is important 

that the owner/operator conduct an internal inspection of the boiler following any hydrostatic test 

where the pressure exceeds Maximum Allowable Working Pressure (MAWP). Pay close 

attention to boiler brace attachment points for loose or damaged fasteners. 

§ 230.36 Hydrostatic testing of boilers. 

Guidance 

A hydrostatic test must be conducted at each 1,472 service day and annual inspection. Other 

factors trigger a hydrostatic test such as any alteration, flush patch, or riveting to a non-stayed 

area of the boiler. Whenever a hydrostatic test is required under this Part, the temperature of the 

boiler shall be between 70 and 120 degrees Fahrenheit. The pressure applied shall be 25% above 

MAWP. 

Note: This section also requires an internal inspection of the boiler anytime a hydrostatic 

test is applied above MAWP. FRA policy requires FRA inspectors to conduct a physical 

internal inspection of the boiler, firebox, and smokebox at each annual inspection, 

provided the boiler is safe to enter as discussed in the guidance above under §230.32 
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(b)(2). If the boiler, firebox, and smokebox is not entered and inspected, FRA inspectors 

shall note, “Interior inspection of boiler not made” and show reason on the inspection 

report using the comment feature. 

§ 230.37 Steam test following repairs or alterations.

Staybolts

§ 230.38 Telltale holes.

§ 230.39 Broken staybolts.

(b) Staybolt replacement.

(c) Assessment of broken staybolts.

(d) Prohibited methods of closing telltale holes.

§ 230.40 Time and method of staybolt testing. 

(a) Time of hammer testing.

(b) Method of hammer testing.

(a) General.

(b) Drilled flexible staybolts. 

(c) Recordkeeping.

(d) Testing at request of FRA inspector. 

Steam Gauges

§ 230.42 Location of gauges.

§ 230.43 Gauge siphon.

§ 230.44 Time of testing.

§ 230.45 Method of testing.

§ 230.46 Badge plates.

§ 230.47 Boiler number.
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Safety Relief Valves

§ 230.48 Number and capacity.

§ 230.49 Setting of safety relief valves.

§ 230.50 Time of testing.

Water Glasses and Gauge Cocks

§ 230.51 Number and location.

§ 230.52 Water glass valves. 

§ 230.53 Time of cleaning. 

§ 230.54 Testing and maintenance. 

§ 230.55 Tubular type water and lubricator glasses and shields.

§ 230.56 Water glass lamps. 

Injectors, Feedwater Pumps, and Flue Plugs

§ 230.57 Injectors and feedwater pumps.

§ 230.58 Flue plugs. 

Fusible Plugs

§ 230.59 Fusible plugs.

Washing Boilers

§ 230.60 Time of washing.

§ 230.61 Arch tubes, water bar tubes, circulators and thermic siphons.

Steam Pipes 

§ 230.62 Dry pipe. 

§ 230.63 Smoke box, steam pipes and pressure parts.

Steam Leaks 
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§ 230.64 Leaks under lagging.

§ 230.65 Steam blocking view of engine crew.

Part 230 Subpart C-Steam Locomotives and Tenders

§ 230.66 Design, construction, and maintenance. 

§ 230.67 Responsibility for inspection and repairs. 

Speed Indicators

§ 230.68 Speed indicators.

Ash Pans 

§ 230.69 Ash pans.

Brake and Signal Equipment

§ 230.70 Safe condition.

§ 230.71 Orifice testing of compressors.

§ 230.72 Testing main reservoirs.

§ 230.73 Air gauges.

§ 230.74 Time of cleaning.

§ 230.75 Stenciling dates of tests and cleaning.

§ 230.76 Piston travel.

§ 230.77 Foundation brake gear.

§ 230.78 Leakage.

§ 230.79 Train signal system. 

Cabs, Warning Signals, Sanders and Lights

§ 230.80 Cabs. 

§ 230.81 Cab aprons.
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§ 230.82 Fire doors. 

§ 230.83 Cylinder cocks.

§ 230.84 Sanders.

§ 230.85 Audible warning device. 

§ 230.86 Required illumination. 

§ 230.87 Cab lights.

Throttle and Reversing Gear

§ 230.88 Throttles.

§ 230.89 Reverse gear.

Draw Gear and Draft Systems

§ 230.90 Draw gear between steam locomotive and tender.

Guidance 

The draw gear between the first and second tenders on geared locomotives (i.e. Shay, Heisler, 

Climax, etc.) are required to be maintained in this same manner as conventional steam 

locomotives and tenders. 

§ 230.91 Chafing irons.

§ 230.92 Draw gear and draft systems.

Driving Gear

§ 230.93 Pistons and piston rods. 

§ 230.95 Guides.

§ 230.96 Main, side, and valve motion rods.

§ 230.97 Crank pins.

Running Gear 

§ 230.98 Driving, trailing, and engine truck axles.

§ 230.99 Tender truck axles.
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§ 230.101 Steam locomotive driving journal boxes. 

§ 230.102 Tender plain bearing journal boxes. 

§ 230.103 Tender roller bearing journal boxes.

§ 230.104 Driving box shoes and wedges. 

§ 230.105 Lateral motion.

Trucks, Frames and Equalizing System. 

§ 230.106 Steam locomotive frame. 

§ 230.107 Tender frame and body.

§ 230.109 Tender trucks. 

§ 230.110 Pilots. 

§ 230.111 Spring rigging.

Wheels and Tires 

§ 230.112 Wheels and tires.

§ 230.113 Wheels and tire defects.

§ 230.114 Wheel centers.

Steam Locomotive Tanks

§ 230.115 Feed water tanks. 

§ 230.116 Oil tanks.

Appendix A to Part 230 - Inspection Requirements

Guidance 

The lists in this appendix are intended as guidance only. Adherence to this list does not relieve 

the steam locomotive owner and/or operator of responsibility for either (1) completing the 

inspection and maintenance requirements described in this part; or (2) ensuring that the steam 

locomotive, tender, and its parts and appurtenances are safe and suitable for service. 

Technical Bulletins Incorporated for Part 230 
Federal Railroad Administration 

9 - 20

MP&E 98-12 Hydrostatic Testing of Steam Locomotive Boilers 

Section 230.17 of 49 CFR requires "Every boiler, before being put into service and at least once 

every 12 months thereafter, shall be subjected to hydrostatic pressure 25% above the working 

steam pressure. Section 230.18 of 49 CFR states, "The dome cap and throttle standpipe must be 

removed at the time of making the hydrostatic test and the interior surface and connections of the 

boiler examined as thoroughly as conditions permit." In case, the boiler can be entered and 

thoroughly inspected without removing the throttle standpipe, the inspector may make the 

inspection by removing the dome cap only, but the variation from the rule must be noted on the 

margin of the report. "Boiler entered through auxiliary dome" or "throttle standpipe not 

removed." If the boiler cannot be entered because of its construction, it should be so stated. 

"Not entered because..." 

Section 230.19 of 49 CFR states, "When the test is being made by the railroad company’s 

inspector, an authorized representative of the company, thoroughly familiar with boiler 

construction, must personally witness the test and thoroughly examine the boiler while under 

hydrostatic pressure." 49 CFR Section 230.20 requires, "When all necessary repairs have been 

completed, the boiler shall be fired up and the steam pressure raised to not less than the allowed 

working pressure, and the boiler and appurtenances carefully examined." All cocks, valves, 

seams, bolts and rivets must be tight under this pressure and all defects disclosed must be 

repaired. 

Hydrostatic testing is a process whereby a fluid, usually water, is forced into the boiler to 

determine the constructive soundness of the complete boiler structure to withstand such test 

pressure. This test can only be performed properly when all air has been purged from the boiler 

being tested. After all air has been purged from the boiler, the pressure should be slowly 

increased by use of a suitable water pump or other device that will not introduce air into the 

boiler during testing. Air in the boiler under test will defeat the principle of hydrostatic testing. 

Pressures exerted in this manner subjects all internal surfaces and parts of the boiler structure to 

equal pressure. Also of very significant importance is the matter of safety. Water is practically 

incompressible and can store extremely little energy. The energy force exerted is furnished by 

the pump. On the other hand, if air is trapped in the boiler being tested, it will be compressed to 

the test pressure attained and build up an energy source that can be extremely dangerous and 

damaging to the boiler being tested should a failure occur. In the event of a structural failure, the 

trapped air pressure will continue to expend its built-up energy until exhausted. With a true 

hydrostatic pressure, stopping the pump ends the pressure source. 

In almost all boilers of horizontal fire tube type, the highest part of the boiler will be the dome. 

During the filling of the boiler, preparatory to hydrostatic testing, air should be vented from as 

near the top of the dome as possible as pressure can be applied more quickly and easily when 

there is no air present. 

The safety valves are either removed and plugs inserted in their places or else they are closed and 

clamped. An accurate test gauge is applied to the boiler and the pressure must be watched 

closely to see that the prescribed testing pressure is not exceeded, as it is very easy to strain, 
Motive Power and Equipment Compliance Manual 

9 - 21

unduly, some part of the boiler. Cold water is not satisfactory for testing, because the boiler 

plates are cold and contracted to a minimum and leaks could appear. A boiler that is in good 

condition and tight under steam will usually show numerous leaks when full of cold water under 

pressure, so that the use of cold water makes the test unnecessarily severe. 

After all defects, such as leaky seams and broken staybolts and crown stays have been taken care 

of, the boiler is fired up and the pressure raised to not less than working pressure so as to 

determine the permanency of the repair made. 

Broken staybolts are more easily detected by hammer testing when the boiler is under a 

hydraulic test pressure, than when it is not. The reason is that the broken ends may be separated 

slightly. Whereas, when the boiler is not under pressure the broken ends may be in contact, thus 

giving a sound like a good staybolt. 

Attached is further information concerning problems associated with trapped air in boilers during 

hydrostatic testing. 

WHERE AIR CAN BE TRAPPED 

1. If not properly vented or purged during filling of the boiler as described above, air can 

also be trapped in the superheater system if the locomotive is so equipped, or in the piston valves 

and cylinders and related piping, if included in the hydrostatic test. 

2. If the locomotive is provided with a throttle valve located in the dome and type "A" 

superheating, and the throttle valve is opened to permit testing of the superheating system during 

the hydrostatic test, additional air venting procedures will have to be made in order to obtain a 

true hydrostatic or hydraulic block of water during the test. 

3. If the locomotive is provided with a throttle valve located in the outlet side of the 

superheater header, special precautions are very necessary in order to prevent the trapping of air 

in the superheater system. Unless it can be known without a doubt that all air has been purged 

from this system, a true hydrostatic head will not be attainable. It is therefore recommended that 

a suitable blanking plate and gasket be applied to the entrance to the dry-pipe prior to hydrostatic 

testing of boilers and vent the boiler, as previously described, from the highest point of the 

boiler. 

As a matter of information to make you aware of hazard of trapped air, the following example is 

provided, covering a locomotive having a multiple type throttle that is integral with the 

superheater header: 

A locomotive having 1,946 square feet of type E superheating surfaces and having superheater 

units within 202 superheater flues, or 404 unit tubes, will require approximately 34.15 cubic feet, 

within the system. This is equivalent to two cylindrical reservoirs 21 inches inside diameter and 

85 inches in length, a comparable 34.06 cubic feet. The working pressure in this example 

locomotive is 245 psi, requiring a hydrostatic test pressure of 25% above working pressure, or 

306.25 psi. 
Federal Railroad Administration 

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Whether type "A" or "E" systems are provided, during filling of the boiler water enters the dry 

pipe near the top of the dome, as possible, then passes into the unit pipes located below and at 

right angle to the filling water level, and then forces the air from each unit. Type "A" units 

consist of four pipes, and three return ends. In the type "E" system, a unit may consist of four 

pipes and three return ends entering two flues, or as many as eight pipes and three return ends 

entering two flues, or as many as eight pipes and six return ends entering four flues comprising a 

very complex system of pipes and turns. This is compounded when the type "A" or "E" systems 

utilize the multiple valve throttle and all air must be purged from the systems through the throttle 

if it is opened. If the throttle is not opened, all air within the unit system will be compressed by 

the incoming water and leaks will probably appear. 

It is important to know the safe condition of all parts of the locomotive, but other appurtenances 

should not interfere with a proper hydrostatic test of the boiler. 

MP&E 98-9 Steam Locomotive Reports 

Each Regional Administrator will retain Steam Locomotive Report Form 1 (Monthly) and Form 

3 (Annual) in their regional offices for all steam locomotives headquartered in their Region. 

Each year the Regional Director will submit a report which will indicate how many steam 

locomotives are in their Region, where they are housed, what railroad they operate on, and 

whether the locomotive is serviceable, stored and which locomotives are operating under a 

waiver for flues. 

Form 4 (Specification Card) and Form 19 (Alteration Report) will be forwarded to RRS-14 and a 

copy placed in the Regional file. 
10 - 1 

Chapter 10 

Railroad Safety Appliance Standards, Part 231

Introduction

Federal regulations establishing safety appliance standards were issued in 1911 by the Interstate 

Commerce Commission (ICC), which had created the Division of Safety Appliances. Soon, the 

ICC issued several “Orders”. These ICC Orders served the same purpose as today’s FRA 

regulations. In accordance with a statutory directive, the ICC Orders identified the number, 

dimensions, location, and manner of application of all safety appliances. After the formation of 

the FRA in 1967, the Railroad Safety Appliance Standards (49 CFR part 231) were issued in 

1968, using the ICC Orders as a basis for the rule text. In 1974 and 1976, FRA amended the 

Railroad Safety Appliance Standards to add two new sections, §§ 231.29 and 231.30. More 

recently, in 2011, FRA again amended the safety appliance regulations to add two new 

provisions establishing a special approval process for existing industry standards. Despite these 

changes, the present-day regulations retain many similarities in substance and form with the 

original ICC Orders issued beginning in 1911. 

The following guidelines and interpretations have been developed to aid Federal and State 

inspectors conducting inspections for compliance with the Safety Appliance Standards in part 

231. It is important that agency interpretations and policies be adhered to by every inspector 

when conducting these inspections, so that uniformity of compliance activity is achieved. The 

procedures and guidance provided in both this manual and the General Manual should be 

observed when assessing the need for appropriate enforcement actions regarding any 

noncompliance with safety appliance standards. Reports of safety appliance inspections are 

made on the Motive Power and Equipment Inspection Report, FRA Form F6180.96. Violations 

are to be submitted on the Violation of Safety Appliance Law Report, FRA Form F6180.29.

Every rail vehicle (car, locomotive, tender, or similar vehicle) has very specific and defined 

safety appliance requirements. Inspectors must be knowledgeable of the common types of 

vehicles and their unique safety appliance arrangements prior to performing part 231 inspections. 

Inspectors also need to familiarize themselves with the many complexities and requirements of 

the various vehicles that are categorized as “cars of special construction.” A car of special 

construction is required to comply with the Railroad Safety Appliance Standards for the car type 

that it most closely resembles or to the “nearest approximate type” of car. If there are questions 

about a particular car type, the inspector should contact the Regional Specialist for a definitive 

classification. For consistency, the Regional Specialists will follow the guidance established by 

Headquarters. 

Strict liability applies when a railroad uses or allows to be used a vehicle with defective safety 

appliances. If a railroad uses or allows to be used a vehicle that is discovered to have a defective 

safety appliance and the vehicle is not being moved pursuant to the statutory provisions 

contained in 49 U.S.C. § 20303 (previously 45 U.S.C. § 13), appropriate enforcement action 

must be taken. If a railroad is unaware of the existence of a defective condition, it cannot claim 

to be moving the vehicle for repairs and is subject to civil penalties. Inspectors are expected to 
Federal Railroad Administration 

10 - 2 

use sound judgment, along with the guidance outlined in both the General Manual and Chapter 3 

of this manual, when deciding whether the issuance of a violation report is appropriate. 

In order to establish a violation, FRA must prove that the vehicle was “in use” or “allowed to be 

used” with a defective condition. Thus, evidence that the equipment was in use or allowed to be 

used with a defective safety appliance is always necessary to support a violation. FRA will 

consider a vehicle in use or allowed to be used as long as the railroad has or should have 

completed its required inspections and the vehicle is deemed ready for service, even if FRA 

inspects the vehicle prior to any movement or the actual departure. Defects found at this time are 

subject to potential civil penalties. Thus, FRA is not required to wait for a car with a defective 

safety appliance to depart or engage in an actual “haul” in order to assess a violation. If 

inspectors rely on the above interpretation, the violation report must establish that the railroad 

had completed all necessary inspections capable of discovering the defective condition. 

Therefore, evidence must be included in the violation report which establishes the inspector’s 

basis for this finding. Be as specific as possible. Inspectors should include names, if they are 

available and the information is helpful in establishing “use”; however, remember to use 

judgment and discretion in exercising FRA’s enforcement authority. In some situations it may 

not be the best or appropriate approach to include such information (for example, it would not be 

appropriate to include a person’s name if doing so would reveal the indentity of a complainant in 

a complaint-based investigation). In many circumstances the best approach is still to establish 

actual use or movement of the vehicle. 

 

The statutory provisions contained in 49 U.S.C. § 20303 govern the movement of vehicles with 

defective or insecure safety appliances. This only allows the railroad to move the defective 

vehicles from the place where the defect is first discovered to the nearest location where the 

necessary repairs can be made. This movement can either be on the railroad where first 

discovered or at the option of the connecting railroad, on the line of the connecting railroad if the 

move is no farther than the location on the line where the defect was first discovered. Thus in 

order to properly move a car for repairs, the railroad must know the defect exists. There are no 

tagging requirements for safety appliance defects. At interchange, a railroad can refuse to accept 

a defective car. Until the receiving railroad accepts the car by moving it or otherwise exercising 

control over it, it is not liable for civil penalties nor is it required to make any repairs. It should 

be noted, however, that the delivering railroad remains liable for each defective car it tenders in 

interchange.

The statutory provision contained in 49 U.S.C. § 20303 is an affirmative defense to be 

established by the railroad. Theseven elements which must be established are: 

• The car was properly equipped with safety appliances in the beginning. 

• The car became defective while being used by railroad on its line. 

• The railroad discovered the defect prior to movement. 

• The movement was from the place where the defect was first discovered. 
Motive Power and Equipment Compliance Manual 

10 - 3 

• Repairs could not be made at the location where the defect was first discovered. 

• Movement was necessary to make the necessary repairs. 

• The car moved only to the nearest available point where the necessary repairs could 

be made. 

The federal regulations on freight power brakes contain guidelines to be considered by FRA 

inspectors and the railroads in determining what constitutes the nearest location where necessary 

repairs can be performed. See 49 CFR § 232.15(f). The guidelines are equally applicable to 

determining such locations for all safety appliance defects. The guidelines must be applied on a 

case-by-case basis to determine if the railroad acted in good faith in moving defect equipment. 

The following locations should be considered when applying the guidelines discussed in detail 

below: 

• Locations where a mobile repair truck is used on a regular basis. 

• Locations where a mobile repair truck originates or is permanently stationed. 

• Locations with an operative repair track or repair shop. 

• Locations where the railroad performs mechanical repairs other than safety appliance 

repairs. 

 

In determining whether a location noted above is capable of making a particular repair the 

following factors must be considered: 

• The accessibility of the location to persons responsible for making repairs. 

• The presence of hazardous conditions that affect the ability to safely make repairs of 

the type needed at the location. 

• The nature of the repair necessary to bring the car into compliance. 

• The need for railroads to have in place an effective means to ensure the safe and 

timely repair of equipment. 

• The relevant weather conditions at the location that affect accessibility or create 

hazardous conditions. 

• A location need not have the ability to effectuate every type of safety appliance repair 

in order to be considered a location where some safety appliance repairs can be made. 

• A location need not be staffed continuously in order to be considered a location where 

safety appliance repairs can be performed. 
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10 - 4 

• The congestion of work at a location shall not be considered. 

In addition to considering the factors noted above, the following factors must be considered in 

determining whether the location is the nearest location where the necessary repairs can be made: 

• Distance to the location. Although this is a key factor it should not be the 

determining factor. This must be considered in conjunction with all the factors 

previously noted as well as the following safety considerations. 

• The safety of the employees responsible for getting the equipment to or from a 

particular location. 

• The safety hazards involved in moving the equipment in the direction of travel 

necessary to get it to a particular location. 

Inspection Guidance

General Interpretations & Guidance

Although the regulations are precise as to the dimensions, location, and manner of application for 

the various car types; interpretations and guidance have been developed over the years by FRA 

to help clarify ambiguities or correct misinterpretations of the regulations. The following written 

guidance is provided to help the inspector conduct inspections for compliance with the Safety 

Appliance Standards. There is a matrix available in Appendix C that identifies safety appliance 

arrangements on the various cars. 

(MP&E 98-7) Errors in U.S. Department of Transportation’s Safety Appliance Standards 

Booklet Published 1977

Many inspectors use the September 1977 reprint of the Safety Appliances and Power Brake 

Requirements (orange) Booklet when conducting safety appliance inspections. Please note there 

are two textual errors in this book. The first is in the “Note” to § 231.1 on page 9, lines 12 to 23. 

The correct text should read as follows, with the portions associated with the error underlined: 

Note: After December 31, 1976, cars of this type built on or before April 1, 1966, 

or under construction prior to that date and placed in service before October 1, 

1966, must be equipped (as nearly as possible) with the same complement of 

safety appliances, depending upon type, as specified in § 231.27 for box and other 

house cars without roof hatches, or in § 231.28 for box and other house cars with 

roof hatches. Cars built after April 1, 1966, or under construction prior thereto 

and placed in service after October 1, 1966, must be equipped, (depending upon 

type) as specified in § 231.27 for box and other house cars without roof hatches, 

or in § 231.28 for box and other house cars with roof hatches. 

The second textual error involves the omission of two lines after line 12, page 64 in § 

231.30(a)(2). The two lines omitted should read as follows:
Motive Power and Equipment Compliance Manual 

10 - 5 

...1977, seventy percent (70 percent) by October 1, 1978 and all such locomotives 

by October 1, 1979. 

(MP&E 98-13) Interpretation of Sill Step Application, 49 CFR Parts 231.1(d)(2) and 

231.27(c)(2) 

It has been brought to the Office of Safety’s attention that some sill step applications on certain 

types of cars are being considered by field forces as noncomplying conditions under the 

Railroad Safety Appliance Standards when in fact, the sill steps are in compliance. To 

minimize confusion in this area, the following guidelines should be used when considering sill 

step applications. 

49 CFR parts 231.1(d)(2) and 231-27(c)(2) address both, Sill Steps Dimensions 

and provide the minimum standards for cross-sectional area, material, length and 

clear depth. The minimum standard for clear depth is 8 inches. Please note 

carefully the words, "clear depth". Clear depth should be understood as meaning 

a vertical space the width of, and above, the sill step material or strap, and that 

vertical space shall be clear and unobstructed for 8 inches. 

Note how this differs fundamentally from the dimensions requirements for handholds and ladder 

treads in the Safety Appliance Standards which stipulate, “minimum clearance..., 2 inches ....”

No limiting direction orientation for clear space is provided, therefore clearance of 2 inches is 

required in all directions or 360 degrees around the handhold or ladder tread. 

As in all considerations of safety appliances, whether or not the appliance can be used “safely” 

must be considered along with the clearances and dimensions. 

 

(MP&E 98-36) Judgment in the Enforcement of the Safety Appliance Standards 

In the past, FRA inspectors have taken exception to minimal deviations from the measurements 

specified in the Safety Appliance Standards on cars that have been in service with the condition 

for a long period of time without any known incident or casualty. Although these civil penalty 

citations are valid from a strictly technical and legal point of view; from a common sense point 

of view, the cars operated safely for years, so these minimal deviations did not materially reduce 

safety. 

Inspectors tend to view the Safety Appliance Standards as requiring the issuance of civil penalty 

citations if strict adherence to each clearance, size, or placement dimension is not maintained 

(i.e., either the clearance, placement, or size of each safety appliance is within the exact 

dimensions required by the regulation, or it is not). Our world has changed and is no longer that 

simple. The railroad operating environment has drastically changed. Crews are smaller, flat 

switching is rare and the number of run-through trains is much greater—all decreasing the use of 

safety appliances. In addition, the limited resources available to both FRA and the railroads 

require that care be taken to avoid the frivolous use of these resources pursuing minor infractions 

that do not materially reduce safety. 
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10 - 6 

Most of the Safety Appliance Standards were developed nearly 100 years ago in a time when 

almost all cars were of a standard design. Application of the regulations to these cars was simple 

and required little, if any, judgment on the part of the inspector. Today most new cars are “Cars 

of special construction.” See 49 CFR § 231.18. The Safety Appliance Standards for such cars 

must be determined from the “nearest approximate type” of a standard car. Id. As a result, the 

Safety Appliance Standards cannot be applied directly to these cars without exercising good 

judgment. 

Today, inspectors must exercise this judgment, not just take measurements and file exceptions 

for minimal deviations. An exception should be taken when the condition of the safety appliance 

materially reduces safety. For example, a safety appliance with a slight looseness that is still 

firmly fastened with all of the securing bolts in place, or a safety appliance with a slightly 

reduced clearance that is still more than adequate for its intended use does not materially reduce 

safety. However, one court found that a handhold moving as little as 1⁄2 inch was not “firmly 

fastened. ” See Roe v. Port Terminal R.R. Ass’n, 620 S.W.2d 870 (Tex. App. 1981). Therefore, 

exactly what materially reduces safety is not always clear—it is a judgment call often dependent 

on the unique set of conditions governing the operation at the time. 

Some general guidance for exercising judgment in the enforcement of the Safety Appliance 

Standards is as follows: 

• Do not take exception to a noncomplying design feature of a type of car that has a 

long and continuous, safe service history. However, if individual cars of that type or 

class have another noncomplying condition, an exception may be taken. 

• If exertion of a significant force (a force greater than that which would be 

encountered in the normal use or operation of the appliance) is required to move a 

safety appliance, exception should generally not be taken. 

• On the other hand, if the safety appliance moves easily to the touch, exception 

certainly should be taken. 

 

Although safety appliances remain an extremely important part of railroad safety and the 

standards pertaining to these appliances must continue to be enforced, the enforcement of the 

Standards needs to be determined through the exercise of good judgment so that scarce FRA and 

railroad resources are not consumed pursuing minor infractions that do not materially reduce 

safety. 

A thorough sample-car inspection—performed in accordance with the procedures described on 

pages 2-8 through 2-11 of the Motive Power and Equipment Compliance Manual—is the proper 

time to enforce the Safety Appliance Standards strictly. An excellent sample-car inspection will 

ensure safety appliance compliance before that type of car is placed in service. 

Locomotive Applications and Guidance

Although safety appliances for other than steam locomotives are not specifically addressed in 
Motive Power and Equipment Compliance Manual 

10 - 7 

part 231, with the exception of § 231.29, Road locomotives with corner stairways, and § 231.30, 

Locomotives used in switching service, non-steam locomotives still are required to have proper 

safety appliances. It is FRA’s position that non-steam locomotives are addressed in the safety 

appliance standards as “cars of special construction”, see § 231.18, whichrequires that all nonsteam locomotives have as nearly as possible the same complement of safety appliances as 

contained in the categories governing steam locomotives. 

(MP&E 98-68) Locomotives Used in Switching Service–Location End Handholds 

Questions have been raised regarding the placement of horizontal end handholds relative to the 

side of the locomotive as referenced in 49 CFR § 231.30(g)(1)(ii). 

When the switching step regulation was developed, some handholds were installed by measuring 

from the side of the locomotive and some from the side of the end plate. The placement of the 

preponderance of end handholds is measured from the side of the end plate. Electro-Motive and 

General Electric have been and are presently applying subject handholds in relation to the side of 

the end plate. 

FRA will not take exception if application of horizontal end handhold placement is measured 

from either the side of the locomotive or side of the end plate. 

(MP&E 98-48) Securement of Handrail to the Locomotive Carbody North American Cab 

Structure 

Some locomotives having the wide body North American cab configuration have the upper end 

of the front vertical handrail not properly secured to the carbody. The Safety Appliance 

regulation, § 231.30(e)(1)(i) states in part that each vertical handhold “ be securely fastened to 

the locomotive with one-half (1⁄2) inch or larger bolts or rivets... “ 

Some locomotives have the upper end of the front vertical handhold bolted to a bracket that is 

welded to that section of the carbody that comprises the outside of the front sand reservoir. 

Although there appears to be adequate strength in the welded bracket, this is not permitted 

because the regulation specifically requires that the handhold be securely fastened with a bolt or 

rivet. 

However, FRA has permitted welding of some permanent fixtures on locomotives to which 

safety appliances are mechanically fastened. The welding was made under quality controlled 

conditions with a full enclosure penetration weld of the fixture to the locomotive, using modern 

shop welding practices, which provide 100 percent full strength requirements of the joint. 

This condition, if found, is not to be taken as a defective condition, but should be brought to the 

railroad’s attention for corrective action. 

(MP&E 98-25) Burro Crane Requirements 

The following interpretations of the Federal regulations regarding the operation of burro cranes 
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10 - 8 

should be used for consistent compliance and enforcement guidelines: 

1. Chapter 203 – Safety Appliances, § 20302. General requirements (a)(4), which requires 

power driving-wheel brakes on locomotives, applies to a Burro Crane being used to pull 

or push cars on tracks that are part of the general rail system. 

2. Railroad Power Brakes and Drawbars, 49 CFR part 232, states that power brakes are not 

required to be installed on “locomotive cranes” built prior to September 21, 1945. By 

implication, power brakes are required on all locomotive cranes, including Burro Cranes, 

built on or after September 21, 1945. 

3. Chapter 203 – Safety Appliances, § 20302. General requirements (a)(1)(A), which 

requires automatic couplers; (a)(1)(B), secure sill steps and hand brakes; and (a)(2), grab 

irons or handholds; all of which apply to a Burro Crane. 

4. If the Burro Crane is used as a road locomotive, § 231.29 of the Safety Appliance 

Standards, a road locomotive with corner stairways apply. 

5. If the Burro Crane is used as a locomotive in switching operations as defined in § 

231.30(b)(2), the requirements of § 231.30 of the Safety Appliance Standards apply. 

6. Other sections of the Safety Appliance Standards do not appear to apply. 

7. Despite the fact that the Burro Crane is excluded from the definition of “locomotive” 

under § 229.5 of the Locomotive Safety Standards, the Burro Crane is nevertheless 

subject to the statutory requirements of the Locomotive Inspection Act (in particular, the 

requirement that it be safe). In the preamble to the final locomotive rule, FRA explicitly 

recognizes the applicability of the Act by stating that “FRA will continue to implement 

the basic statutory safety requirements with respect to such work equipment by using the 

Special Notice for Repair when appropriate.” (45 FR 21093). 

(MP&E 98-71) Self-Propelled Vehicles Considered to Be Locomotives (excerpted) 

Recently, we have had several inquiries about equipment requirements for self-propelled 

vehicles used to haul revenue freight on the main line. Self-propelled vehicles are used in a 

variety of railroad functions. These vehicles include those built by Trackmobile Inc., Shuttle 

Wagon, Mitchell Equipment Corporation, and Brandt RoadRailer. 

.... 

When a self-propelled vehicle is used to move freight over the railroad, it will be considered a 

locomotive and must comply with applicable regulations. Even though these vehicles do not 

resemble a standard locomotive, the purpose for which they are being used requires compliance 

with 49 CFR parts 223, 229, 231 and 232. 

The self-propelled vehicles are unique in construction, appearance, and use. Many of these 
Motive Power and Equipment Compliance Manual 

10 - 9 

vehicles currently being used have already been modified by the manufacturers (as closely as 

construction would permit) to bring them into compliance with Federal regulations. FRA 

acknowledges that this equipment has a place in a well-rounded rail transportation system. In an 

effort to recognize the unique characteristics of these vehicles, FRA inspectors should exercise 

enforcement discretion and good judgment in analyzing an operation where self-propelled 

vehicles are used for train movements. 

The following specifications should be used by inspectors for enforcement guidance: 

.... 

13. Switching steps as defined in § 231.30. 

14. Four horizontal handholds secured to the back and front ends of the vehicle, secured by 

bolts or other acceptable mechanical fastener. (§ 231.30). 

15. Vertical handholds painted in contrasting colors and secured by bolts or other acceptable 

fasteners. (§ 231.30). 

16. Must be equipped with automatic couplers, to prevent the necessity of someone going 

between the vehicle and car for the purpose of coupling or uncoupling. (§ 231.30). 

.... 

Items deemed to be safety-related, which cannot meet specified requirements, will have to be 

addressed through the waiver process. 

§ 231.15 Steam locomotives used in road service.

The vast majority of, if not all, steam locomotives in use today are used in tourist and excursion 

road service. The focus of safety appliance inspection on steam locomotives should be directed 

at whether or not the appliance is structurally sound, securely fastened and located, provides 

proper clearance, is unobstructed, and is safe to use. 

§ 231.15 Specifications common to all steam locomotives.

Steam locomotives with Vanderbilt-type tenders require additional handrails, running boards and 

handholds that vary from other tenders. 

§ 231.16 Steam locomotives used in switching service. 

The regulations pertaining to steam locomotives in switching service require footboards. 

However, inspectors should not take exception to steam locomotives that have had the 

footboards removed. Conversely, many steam locomotive owners/operators have elected not to 

remove the footboards from their locomotives for historical purposes, but may prohibit railroad 

personnel from occupying the footboard while the locomotive is moving. In either case, the 
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10 - 10 

focus of safety appliance inspection on steam locomotives should be directed at whether or not 

the appliance is structurally sound, securely fastened and located, provides proper clearance, is 

unobstructed, and is safe to use. 

§ 231.30 Locomotives used in switching service. 

Locomotives used in switching service, regardless of built date, must be in full compliance with 

49 CFR § 231.30. However, some relaxation of the regulations is allowed with respect to 

switching step height and width for six-axle locomotives in switching service, built prior to April 

1, 1977. 

 

It should be noted that this section specifically allows for the fastening of the switching step to 

the switching step bracket by weld, provided the weld is at least twice the strength of a bolted 

attachment. Since this issue can obviously be subjective and open to interpretation, inspectors 

should exercise discretion. Generally speaking, most welds applied during manufacture are as 

strong as or stronger than any mechanical fastener made. Welding by the manufacturer is 

typically performed under controlled circumstances and in accordance with strict Weld 

Procedure Specification (WPS). The problems associated with welding occur when no WPS 

exists, as is the case in most railroad locomotive shops. When inspecting switching steps that 

have been applied by weld, carefully inspect the weld for discontinuities such as incomplete 

fusion, undercut, overlap, porosity or inclusions. If any of these defects exist in the weld, the 

integrity of the weld should be questioned. 

The outer edge of the bottom switching step must be illuminated on all locomotives built after 

March 31, 1977. Locomotives built prior to March 31, 1977, may be illuminated, or have the 

outer edge of the switching step painted a contrasting color. If multiple locomotives (two or 

more) are used in switching service, only the front switching steps of the leading locomotive and 

the rear switching steps of the trailing locomotive must be illuminated or painted a contrasting 

color, depending on built date. Vertical handholds must also be painted a contrasting color. In 

addition, a minimum of 21⁄2 inches of clearance must be maintained through the entire length of 

the vertical handhold. 

§ 231.29 Road locomotives with corner stairways. 

Road locomotives without corner stairways may not be used in switching service after 

September 30, 1979, except for passenger cars switching service at passenger stations. (See § 

231.30 (a)(3)) 

Freight and Passenger Car Applications and Guidance

Safety Appliance Fasteners (MP&E 98-14) 

The Railroad Safety Appliance Standards, 49 CFR part 231, require that safety appliances and 

their brackets be secured by 1⁄2-inch bolts with nuts outside (when possible) and riveted over, or 

with not less than 1⁄2-inch rivets. Additionally, in order to comply with the Safety Appliance 

Regulations, there must be a deformation of the threads to prevent the fastener from becoming 
Motive Power and Equipment Compliance Manual 

10 - 11 

insecure . This can be accomplished by one of the following methods: 

 

1. Rivet the fastener; 

2. Check the threaded portion of the bolt nearest the fastener with a chisel to 1⁄8-inch 

depth at two locations; or 

3. Apply weld to the threaded portion of the threads, so as to deform them. 

Figure 1 - A typical two-part mechanical fastener 

Additional approved safety appliance securement fasteners are: one-and-two piece rivets (Huck 

bolt—See Figure 1), bolts and nuts, Unilock, Disclock, and Nordlock fasteners when properly 

applied. 

Part 231 is explicit in requiring that handholds be securely fastened. By definition, secure means 

free from danger or risk of loss; free from fear or doubt; and not likely to fail or give way. 

The Federal Railroad Administration’s (FRA) longstanding policy concerning the securement of 

all safety appliances requires that safety appliances or supports for safety appliances must be 

mechanically fastened. Brackets or supports that are applied to a car structure (other than a tank 

car tank) solely for the securement of safety appliances are to be mechanically fastened to the car 

structure. 

Many years of railroading experience has shown that welds are not uniform and are subject to 

failure, despite improvements in welding procedures. Cracks and breaks in welds are difficult to 
Federal Railroad Administration 

10 - 12 

detect during inspections. Therefore, welding is not considered to meet the definition of secure. 

This is particularly evident at repair facilities, where quality of workmanship is not always 

assured. 

Safety appliances for other than steam locomotives are not addressed in Part 231, with the 

exception of § 231.29, Road locomotives with corner stairways and § 231.30 Locomotives used 

in switching service. This does not mean that non-steam locomotives are not required to have 

proper safety appliances. It is FRA’s position that other than steam locomotives must have 

proper safety appliances and are covered as cars of special construction. 

This requires that locomotives other than steam have as nearly as possible the same complement 

of safety appliances as contained in the categories governing steam locomotives. 

However, FRA has not enforced the deformation of threads of bolts used to secure safety 

appliances on locomotives. These appliances are usually secured by self locking nuts and/or 

lock washers, and, to our knowledge, have not presented a safety problem. 

Exception should only be taken when the safety appliances on other than steam locomotives are 

insecure or presenting a potential safety hazard to railroad employees. Out-of-service form 

F6180.8 should only be issued if the safety appliance is defective to the extent it creates an 

immediate unsafe condition. 

(MP&E 98-22) Adjustable Handhold/Ladder Tread 

The adjustable handhold/ladder tread is 3/4-inch in diameter. Its length may be adjusted as 

needed, by the application of a 1/4-inch roll pin into the desired hole. The remaining portion is 

to be cut off, leaving a smooth surface. 

In 1988, the Federal Railroad Administration (FRA) ruled that this adjustable safety appliance 

meets the specified requirements, if properly applied. However, FRA expressed concern of the 

possibility of improper application, such as the substitution of the roll pin, improper securement, 

etc. 

If any deficiency is found concerning this safety appliance, such as substitution of the roll pin, 

improper securement, etc., it should be reported to the regional MP&E Specialist with all 

pertinent information, including photographs. The Specialist is to promptly advise the MP&E 

Staff Director. 

(MP&E 98-49) Dimensions Applicable to Handles of Uncoupling Levers 

In the past, some inspectors have taken exception to the handles of bottom operated uncoupling 

levers being more than 6 inches from the side of the car. 

Section 231.1(k)(2) states in relevant part: (i) Handles of uncoupling levers, except those shown 

on Plate B or of similar designs, shall be not more than 6 inches from sides of car. (ii) 

Uncoupling levers of design shown in Plate B and of similar designs shall conform to the 
Motive Power and Equipment Compliance Manual 

10 - 13 

following prescribed limits: (iii) Handles shall be not more than 12, preferably 9, inches from 

sides of cars. Center lift arms shall be not less than 7 inches long. 

The top operated uncoupling lever shown in Plate B is similar in design to bottom operated 

uncoupling levers and are fundamentally the same, as both are operated in the same manner by 

an upward lift of the uncoupling lever handle to disengage the coupler lock block. 

The reference in § 231.1(k)(2)(i) to uncoupling levers of other than Plate B design requires that 

the uncoupling lever handle be not more than 6 inches from side of car. This refers primarily to 

those uncoupling levers which are operated by a downward motion of the uncoupling lever either 

by hand or foot. This type of uncoupling lever could be operated from the side ladder while the 

car was in motion. 

Therefore, FRA will not take exception to bottom operated uncoupling levers that are similar in 

design to that shown in Plate B, unless the uncoupling lever handle is more than 12 inches from 

the side of the car. 

Also for your information, the Association of American Railroad’s (AAR) Rule 22 for bottom 

operated uncoupling levers shows the maximum distance of the uncoupling lever handle to be 12 

inches from the side of the car. 

(MP&E 98-51) Definition of Left and Right — A and B End 

The purpose of this bulletin is to provide Railroad Safety Inspectors with the position the Federal 

Railroad Administration has adopted, as a result of the work of an MP&E Technical Resolution 

Committee, for determining and reporting the location of noncomplying and/or defective railroad 

car components. The definition of “left” and “right” is defined in § 231.19: 

“Right or Left refers to the side of person when facing end or side of car 

from ground” 

 

This bulletin further identifies the “A” and “B” end of the car from which the definition will be 

applied and provides additional guidance for uniformly identifying various components on a car. 

The railroad industry’s generally established and accepted practice for determining the location 

of applicable components on rail cars equipped with four, six, or eight wheel trucks is as follows: 

• The B end of a car is determined by the location of the hand brake. The end of the 

car on which the hand brake is located is the B end. The opposite end of the car is 

known as the A end. On cars equipped with hand brakes on both ends, the “A” and 

“B” end shall be determined as stencilled. 

• When facing the B end of the car, the car is divided into four sections known as BR, 

BL, AR, and AL. The order of applicable components on the right side of the car 

shall be known as R1, R2, R3, etc. The order of applicable components on the left 

side of the car shall be known as L1, L2, L3, etc... See Figure 2. 
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10 - 14 

• Beginning at the B end of the car, brake beams shall be numbered consecutively, see 

Figure 3. 

The railroad industry’s generally established and accepted practice for determining the location 

of applicable components on articulated and multi-level cars is as follows: 

Figure 2 - The definitions of “A” end, “B” end, Left, Right and component order numbers 

Figure 3 - The definition of break beam numbering order 
Motive Power and Equipment Compliance Manual 

10 - 15 

• The “B” end of the car is determined by the location of the hand brake. The end of 

the car on which the hand brake is located and is stenciled “B end” shall be known as 

the B end of the car. The end unit opposite the “B” end is the “A” end. The unit 

adjacent to the B end shall be known as the “C” unit and each additional unit will be 

stenciled consecutively and alphabetically from the “B” end toward the “A” end. See 

Figure C. For cars equipped with multiple hand brakes, report the unit location. 

• When facing the “B” end of the car, the right side is known as the “R” side and the 

left side is known as the “L” side. Wheel sets and applicable components will be 

numbered consecutively from the “B” end to the “A” end, 1 through 9. Applicable 

components above 9 will be identified alphabetically in reverse order from Z (Z, Y, 

X, W, etc.) until the last wheel set on the A unit is identified, see Figure 4. 

 

 

Figure 4 - Definition of the location of applicable components on articulated and multi-level cars 
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10 - 16 

• Facing the B end of the car, the articulated connection locations will be lettered 

beginning with C and will continue consecutively and alphabetically from the B end 

toward the A end. See Figure 5. 

• The end truck on the B end will be location B and the end truck on the A end will be 

location A. Starting with the first truck inboard from the B end, the truck location 

will be lettered beginning with C and will continue consecutively and alphabetically 

from the B end toward the A end. See Figure 5. 

 

• The drawbar connection will be reported as the combination of the locations of the 

two trucks closest to the drawbar. See Figure 6. (i.e. CD, EF, GH, etc.) The end 

truck on the B end will be location B and the end truck on the A end will be location 

A. Starting with the first truck inboard from the B end, the truck location will be 

lettered beginning with C and will continue consecutively and alphabetically from the 

B end toward the A end. See Figure 6. 

Figure 5 - Definitions of the articulated connection locations and truck locations 
Motive Power and Equipment Compliance Manual 

10 - 17 

 

The above guidance should be applied when reporting the location of applicable non-complying 

components under the provisions of part 215, 231, and 232. It can also be applied to passenger 

cars unless the passenger railroad utilizes some other generally accepted method of identifying 

the location of passenger car components (e.g. No. 1 end , No. 2 end, etc). 

(MP&E 98-18) Aluminum Safety Appliances 

In the past, exception has been taken to various cars equipped with aluminum safety appliances: 

ladder treads, handholds, and sill steps. 

FRA’s Office of Research and Development has confirmed that the ladder treads, handholds of 

circular cross-section, 13/16-inch diameter and sill steps, 5/8-inch thick and 2 inches wide, when 

constructed of 6061-T6 aluminum alloy, exceeds the current Federal Railroad Administration’s 

requirements. Therefore, no exception should be taken to this material. 

Hand brakes

(MP&E 98-53) Hand brake Chains 

It has been brought to our attention that freight cars of recent construction are being equipped 

with hand brake chains that are not in compliance with FRA regulations. Hand brake chains are 

described in the present Safety Appliance Standard Regulation, § 231.27(a)(2)(vi), as follows: 

Figure 6 - Definitions of drawbar connection and truck location 
Federal Railroad Administration 

10 - 18 

All chains shall be not less than nine-sixteenths (9/16) inch BBB coil chain. 

The Association of American Railroads (AAR) Manual of Standards S-404-74, 2.1.9, has the 

following requirements for hand brake chains: 

Hand brake power chain shall be 9/16 inch BBB coil chain or meet the minimum 

specification (working load 5,875 lbs., proof test of 11,750 lbs.) of sufficient 

length so that the distance from center line of lower attaching rivet hole in 

housing to center line clevis rivet is 21- 9/16 inches. 

It has been determined that both the 3/8 inch alloy chain and the 1⁄2-inch steel alloy chain 

currently being used by new car manufacturers exceeds the specifications for the 9/16-inch BBB 

coil chain. 

Therefore, in accordance with 49 CFR § 231.27(a), exception should not be taken to hand brake 

chains that provide the same degree of safety, or a greater degree of safety, as the 9/16-inch BBB 

coil chain. 

The 9/16-inch BBB coil chain is no longer being used by hand brake manufacturers. 

(MP&E 98-26) Hand brakes–Articulated Cars 

Hand brake performance requirements, as specified in 49 CFR part 231, include the following: 

• Must be an efficient design 

• Must operate in harmony with the power brake 

• Must provide equal or greater total force on the brake shoes as the brake cylinder with 

50 psi air pressure 

• One hand brake per car. 

The AAR is more specific in their requirements in that a minimum braking ratio of 11 percent 

must be achieved at the brake shoes with a specified force output at the hand brake (equivalent to 

125 pounds on the rim of the wheel). Further, the hand brake force must act on one-half of the 

axles including the “B” end truck. If these requirements cannot be met with a single hand brake, 

a second hand brake must be applied with appropriate stenciling at each hand brake location. 

On some articulated multi-platform cars, it is not feasible to apply the hand brake force to half 

the axles with one hand brake and a second hand brake has been applied at the opposite end (“A” 

end) of car. 

FRA takes no exception to this practice, if the following conditions are met: 
Motive Power and Equipment Compliance Manual 

10 - 19 

• Stencils must be placed adjacent to each hand brake advising that the car is equipped 

with two hand brakes. 

• Each hand brake shall be so located that it can be safely operated while car is in 

motion. 

• The hand brake force should comply with AAR standards. 

(MP&E 98-35) Multi-Unit Articulated Flat Cars–Crossover Platforms 

Trailer Train Company’s (TTAX) 5-unit All Purpose Spine Cars are equipped with hand brakes 

that face outward at each end of the 5-unit consist. The hand brake arrangement is designed so 

that it can be operated while standing on the sill step or from the ground. 

When a 48-foot container is placed on the “A” end unit, the end “crossover” platform is partially 

covered by the container and has only 10 inches exposed. The “crossover” platforms on these 

TTAX cars and/or platform extensions on other multi-unit articulated flat cars are not a 

requirement of the current safety appliance standards. Additionally, they are not used for the 

proper operation of the hand brakes. 

Therefore, FRA will not take exception to these TTAX five-unit All Purpose Spine Cars when 

loaded on the A and B units with 48-foot containers that partially cover the end “crossover” 

platforms. 

However, FRA requires that safety appliances or supports for safety appliances be mechanically 

fastened. Brackets that are applied to a car structure other than a tank car, solely for the 

securement of safety appliances, are to be mechanically fastened to the car structure. 

(MP&E 98-5) Standard Level and Low Level Auto Rack Cars 

Since the origination of the radial door and its application to auto rack cars, many clearance 

problems have developed. Because of the nature of these problems, the vertical relationship of 

the side ladders and sill steps has been altered in such a manner that there are variations of 

misalignment from 5 to 13 inches. The Federal Railroad Administration (FRA) feels that this 

has created a potential safety hazard and that FRA needs to establish guidelines to implement 

improvement in this area. FRA and the Car Manufacturers determined that the following 

dimensions be adopted: 

Standard Level Cars Relationship of Sill Step to Side Ladder

 All cars 2-3/16 inch maximum 

Low Level Cars

 Built 1978 and prior 5-inch maximum 

 Built after 1978 4-inch maximum 

Flat Cars
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10 - 20 

(MP&E 98-16) DODX 40000 Series Flat Cars 

In the past, inspectors have questioned whether DODX 4000 series flat cars are in compliance 

with 49 CFR § 231.6(a)(3)(i), which requires that “Each hand brake shall be so located that it can 

be safely operated while car is in motion.” 

These cars are designed to have a 21⁄2 by 8-inch slot in the car floor near each corner. These slots 

are considered by FRA as “grab holes,” so that the hand brake can be safely operated using this 

“grab hole” when the car is in motion. 

These cars were built primarily to haul M-1 tanks, which are 12 feet wide. The car floor is only 

10-feet 8-inches wide. The hand brake is located so that the tanks can be loaded or unloaded. 

Also, it has been reported that these cars have a missing bottom rod safety support. 

These cars are equipped with Buckeye 6-wheel trucks with truck-mounted brakes. Because of 

the truck mounted brakes, bottom rods requiring safety supports are found only on the hand 

brake truck. There are two bottom rods. One is equipped with two safety supports, while the 

other has only one. The truck, as designed, lacks a bracket or other location to which an 

effective fourth safety support can be attached. The brake rod in question measures 35 inches 

between pivot points. The loss of a connecting pin at the unsupported end of the rod would 

cause the rod to drop a 1⁄2-inch over a distance of 7 inches before it encountered the existing 

safety support. The minimum clearance above the rail would still be more than 21⁄2 inches. 

Inspectors should take no exception to cars so equipped. 

 

(MP&E 98-69) Safety Appliance Arrangements on Flat Cars 

§ 231.6 specifies the minimum requirements for safety appliances on flat cars. However, over 

the years, other arrangements have been agreed upon without being incorporated into the 

standards. Therefore, new and reassigned employees, as well as new car builders, may not be 

aware of such agreements. 

One revised arrangement of horizontal side handholds occurred when the TTAX decided to 

eliminate the vertical handhold on long bridge plates. This side handhold arrangement follows. 

Side Handholds: 

• Dimensions: Same as specified for flat cars, except length not less than18-inches, 

and diameter not less than 1-inch when legs are extra long. 

• Manner of Application: Same as specified for “Box and Other House Cars.” 

• Location: One over each sill step on top of rub rail projecting upward, not less than 

27 nor more than 34 inches above tread of sill step. Clearance at outer end should 
Motive Power and Equipment Compliance Manual 

10 - 21 

not be more than 8 inches from end of car. 

All other safety appliances on piggyback cars should conform to those specified for flat cars. 

Also, additional handholds provided to facilitate use of hand brakes, including handholds on stub 

bridge plates, should be retained. 

Any flat car that has a low-mounted side hand brake, should be equipped with a second handhold 

at the hand brake corner 15 to 16 inches above the handhold described previously. The tread of 

the sill step at this location should be widened to not less than 4 inches and be provided with an 

anti-skid surface. When possible the length of such sill step should be increased to not less than 

14 inches. 

 

The additional handholds and wider sill step to facilitate the use of the low-mounted side hand 

brake were agreed upon because of the requirement in § 231.6(a)(3)(i), “Each hand brake shall 

be so located that it can be safely operated while car is in motion.” The inspector should 

become familiar with these arrangements. 

(MP&E 00-07) Safety Appliance Arrangements on Flat Cars with Low-Mounted Side Hand 

Brakes 

Section 231.6 specifies the minimum requirements for safety appliances on flat cars. However, 

over the years, other alternative safety appliance arrangements have been used by the industry 

and permitted by FRA in order to accommodate the unique designs of various flat cars. This is 

particularly true with regard to flat cars equipped with low-mounted side hand brakes. FRA 

previously issued guidance related to these types of flat cars in Technical Bulletin (TB) MP&E 

98-69. This bulletin is intended to supplement that previously provided guidance. 

Section 231.6(a)(3)(i) requires that “Each hand brake shall be so located that it can be safely 

operated while car is in motion.” FRA has consistently viewed compliance with this provision as 

dependent on whether safe operation is possible given the intended location of the hand brake in 

relation to other safety appliances necessary for its safe operation. As a result, merely providing 

the handholds explicitly required by § 231.6, does not guarantee that a hand brake can be safely 

operated. For example, flat cars with low-mounted side hand brakes may need to be equipped 

with additional safety appliances, over and above those specifically required in § 231.6, in order 

for the hand brake to be safely operated while the car is in motion. 

TB MP&E 98-69, incorporating guidance contained in previous FRA technical bulletins dating 

back to the mid-1970’s, contained guidance regarding one safety appliance arrangement that was 

acceptable to FRA on flat cars equipped with low-mounted side hand brakes to ensure 

compliance with the requirement contained in § 231.6(a)(3)(i). In that TB, FRA made clear that 

it would not take exception to such flat cars if: (i) they were equipped with a second handhold at 

the hand brake corner 15 to16 inches above the handhold located over each sill step; (ii) the tread 

of the sill step at that location was widened to not less than four (4) inches and was provided 

with an anti-skid surface; and (ii) when possible, the length of such sill step was increased to not 

less than 14 inches. Such guidance, while not imposing new requirements, provides the industry 

with certainty about how to comply with the existing requirement at § 231.6(a)(3)(i). 
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Recently, FRA has discovered that the safety appliance arrangements on numerous flat cars with 

low-mounted side hand brakes are being modified to eliminate the second handhold described 

above. This handhold is being removed due to the constant damage being sustained by the 

appliance during the loading and unloading of the flat cars. In order to prevent the continuous 

damage to these necessary appliances and to ensure the safety of employees while applying the 

hand brake on these flat cars, FRA believes that additional guidance is needed to provide an 

alternative to the safety appliance arrangement described in TB MP&E 98-69. 

Consequently, in addition to the safety appliance arrangement described above, FRA will not 

take exception to the safety appliance arrangement on any flat car equipped with a low-mounted 

side hand brake if: (i) the flat car is equipped with a second handhold at the hand brake corner 

mounted on the end sill not more than 12 inches from the end of the car so as to align with the 

outer edge of the sill step and not less than 2 inches, nor more than 6 inches, from the side of the 

car; (ii) the handhold is a minimum of 18 inches in width and not less than 15 inches, nor more 

than 21 inches, in height; (iii) the tread of the sill step at this location is widened to not less than 

4 inches and is provided with an anti-skid surface; and (iv) when possible, the length of such sill 

step is increased to not less than 14 inches. 

As noted above, the guidance contained in TB MP&E 98-69 remains in effect, and the present 

guidance merely provides an additional safety appliance arrangement to which FRA will not take 

exception. Although this TB recognizes two safety appliance arrangements that are acceptable to 

FRA for meeting the requirement contained in § 231.6(a)(3)(i), with regard to flat cars with lowmounted side hand brakes, there may be other safety appliance arrangements that would also 

ensure compliance with this requirement on such flat cars. However, merely removing a 

handhold that followed the guidance of TB MP&E 98-69 will likely result in a car that does not 

comply with § 231.6(a)(3)(i). 

Covered Hopper Cars

(MP&E 98-23) Covered Hopper Cars – Running Board Extensions 

There have been several inquiries concerning running board extensions. 

FRA's position is that a running board end extension is not required if the end of the longitudinal 

running board is at least 6 inches from the vertical plane and the longitudinal running board 

extends at least the entire length of the roof. In other words, if the longitudinal roof running 

board does not extend at least the entire length of the roof, a running board extension is required. 

 

Roof Hatch/Walkway Blockage

FRA does not believe open hatch covers on top of cars to be a significant safety issue due to 

prohibitions of individuals on the top of cars and the ease with which the obstruction can be 

rectified. If an inspector finds a significant number of instances of open hatch covers, the 

inspector should contact the Regional Specialist and/or Headquarters, prior to issuing any 

violations. 
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Cars of Special Construction

 

(MP&E 98-17) Bulkhead Flat Cars 

Although the Safety Appliance Standards do not specifically address bulkhead flatcars, these 

cars would be considered a car of special construction. [Section] 231.18 states that cars of 

special construction must have, as nearly as possible, the same complement of handholds, sill 

steps, ladders, hand brakes, and running boards that are required for cars of the nearest 

approximate type. 

FRA is of the opinion that this car, with fixed ends above the floor, most closely resembles cars 

described in § 231.27, “Box and other house cars without roof hatches or placed in service after 

October 1, 1966.” 

Therefore, bulkhead flat cars built or placed in service after October 1, 1966 should comply as 

nearly as possible with all the requirements of this section. 

(MP&E 98-19) “Differential” 100 -Ton Covered Hopper Cars Built by the Thrall Car 

Manufacturing Company. 

On “pressure differential” 100-Ton Covered Hopper Cars, built by the Thrall Car Manufacturing 

Company, the end platform and end platform handholds are less than 60 inches long because of 

structural considerations. 

Structural justification for the design is to place supports on the flat end sheet, at locations that 

will prevent over-stressing the sheet when the car is pressurized. 

A letter was sent to the Thrall Car Manufacturing Company, General Electric, and Rail Car 

Services with the following information: 

 

• Concerning the safety appliance arrangement on “Differential” 100-ton covered 

hopper cars. Specifically, the end platforms and horizontal end platform handholds 

having a length of less than 60 inches. 

• Please be advised that due to the structural design of these cars (curved-sided), FRA 

will not take exception to the end platforms and horizontal end platform handholds 

having a length of less than 60 inches. FRA will consider these cars to be of special 

construction and conform to those requirements, as specified in § 231.18. 

Coil Steel Cars

Over the past several years numerous concerns have been raised regarding the classification of 

Coil Steel Cars under the Safety Appliance Standards contained in 49 CFR part 231. Because 
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Coil Steel Cars do not conform to any of the car types specifically identified in part 231, these 

cars must be considered cars of special construction, pursuant to 49 CFR § 231.18, which 

states: 

Cars of construction not covered specifically in the foregoing sections in this part, 

relative to handholds, sill steps, ladders, hand brakes and running boards may be 

considered as of special construction, but shall have, as nearly as possible, the 

same complement of handholds, sill steps, ladders, hand brakes, and running 

boards as are required for cars of the nearest approximate type. 

Historically, the determination of what type of car specifically identified in part 231 is the 

“nearest approximate type” to a Coil Steel Car has differed depending on the manufacturer, 

railroad, and/or FRA personnel involved in making the decision. For the most part, the differing 

views are the result of the reality that all Coil Steel Cars are not designed or manufactured in an 

identical fashion. Thus, although this type of car is universally referred to as a “Coil Steel Car,” 

the cars have unique designs and are constructed differently depending on the manufacturer of 

the car and/or the date on which the car was built. These variations in the design and 

construction of Coil Steel Cars have resulted in a number of different interpretations relating to 

what constitutes the car of “nearest approximate type” under § 231.18. 

To date, FRA has generally determined that the nearest approximate type of car, specifically 

identified in part 231, to a Coil Steel Car is either a flat car or a low-sided gondola car. See 49 

CFR §§ 231.6 and 231.5. FRA considers either of these applications to be appropriate and 

acceptable. Thus, if a Coil Steel Car conforms to the requirements related to either of the above 

noted car types, then no exception should be taken. When inspecting Coil Steel Cars, FRA 

inspectors must base their determination of what constitutes the “nearest approximate type” of 

car under part 231 on previous FRA sample car inspections, if one was performed, and upon the 

historical application of the regulations to that particular car. 

Furthermore, historically, FRA has not taken exception to covers on coil steel cars as to the 

location and fastening of handholds, railings, or covers that are mixed on a different car than the 

original design except, if a cover handhold or railing does not have proper clearance, is broken, 

or is included as part of the hand brake arrangement to support the operation of a hand brake 

while the car is in motion. 

In situations where an FRA Inspector cannot determine the “nearest approximate type” of car, 

the following procedures shall be applied: 

• The inspector should request from the operating railroad the letter issued by FRA, 

relating to the sample car inspection performed on that series of cars, indicating the 

sample car inspection “car type” as determined by FRA headquarters. If the car 

conforms to the requirements related to “car type” indicated by the sample car 

inspection, then no exception should be taken. 

• If the operating railroad cannot produce the above-described document or a sample 

car inspection was not performed, the “nearest approximate type” of car will be 
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determined by the FRA inspector and the inspector will document all noncomplying 

conditions on FRA Form F6180.4a to include photos. 

• FRA’s Inspector should also request an UMLER or AAR report that indicates the 

“car type” as determined by the industry from the operating railroad. 

• The above-noted information should be sent to the regional MP&E Specialist, who 

will then submit all of the above information to headquarters with a request for 

guidance. 

Tank Car Applications and Guidance

(MP&E 98-31) Safety Chains on Tank Cars 

Operating platforms on tank cars without underframes are addressed in §231.21(j)(3), which 

states: 

(3) Location. (i) Operating platform to be of sufficient length to provide access to all 

operating fittings. Ladder to be located on sides of car at center. 

(ii) The safety railing shall enclose the operating platform, manway and fittings used in 

the loading and unloading of the tank. Railing shall be open only at the ladders where it 

shall extend in a vertical direction down to, and be securely attached to the platform. 

Maximum width of opening, twenty-four inches. 

Additionally, there are tank cars constructed with top-operating platforms which have end 

ladders at each end of the tank car, rather than side ladders, in accordance with § 231.18, Cars of 

special construction.

Therefore, openings in the operating platform allowing access to the ladders do not require safety 

railing (safety chain) enclosure. All other openings of the operating platform require enclosure. 

See Figures 7 and 8. 

Figure 7 - Noncompliance conditions for tank car operating platform 
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Figure 8 - Compliant railing on tank car operating platform 

(MP&E 00-06) Manufacture and Repair of Operating Platforms and Operating Platform Safety 

Railings On Tank Cars Without Underframes 

Section 231.21(j) specifies the minimum requirements for operating platforms on tank cars 

without underframes. However, many variations in the manufacture and repair of these 

platforms and the platform safety railings have been in use for a number of years, causing 

confusion among FRA inspectors and manufacturers as to which methods comply with Federal 

regulations. 

In order to establish consistency within the industry, FRA hosted a committee comprised of 

representatives from FRA, AAR, Railway Progress Institute, and several major tank car 

manufacturers. Based on the information provided at the committee meetings and FRA’s prior 

enforcement of the requirements pertaining to operating platforms on these tank cars, this 

technical bulletin and its attachments provide guidance regarding the various methods of 

manufacture and repair of operating platforms and operating platform safety railings on these 

tank cars that are acceptable to FRA. 

Section 231.21(j) requires the operating platforms and related safety railings on tank cars without 

underframes to be “securely attached” or “securely fastened.” FRA has a longstanding 

interpretation of these phrases which requires that the safety appliances be mechanically 

fastened. See MP&E Technical Bulletin 98-14. However, FRA believes it is necessary and 

consistent with both safety and FRA’s previous enforcement of Part 231 to exercise its 

enforcement discretion and continue to allow the weldment of certain portions of the safety 

appliances on these operating platforms. Tank cars have been manufactured for numerous years 

 with operating platforms that have handrails welded to stanchions and stanchions welded to car 

body brackets. Tank cars built in this manner have operated for decades without creating any 

known safety hazard. Thus, FRA will not take exception to existing equipment with these types 

of safety appliance arrangements, but will require mechanical attachment of such appliances on 

all tank cars with operating platforms built after January 1, 2000, and when repairs are required 

on equipment built prior to that date. See Exhibit G, Figures 17 and 18. 

Similarly, FRA has allowed safety railings on operating platforms to be repaired using weldment 

under certain controlled conditions. Thus, the guidance contained in this bulletin merely 

acknowledges repair and fabrication requirements for safety railings on operating platforms that 

are consistent with existing practices to which FRA has not taken exception in the past. FRA 
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believes that the fabrication and repair requirements related to handrails, contained in Exhibits A 

and F, Figures 13 through 16, do not result in a reduction of the structural integrity of the 

railings. Furthermore, although weldment is permitted at intermediate points in the railing, the 

railing is mechanically fastened at the end locations where it is attached to the operating platform 

or stanchion. 

FRA will exercise its enforcement discretion and not take exception to the factory weldment of 

safety appliance brackets at intermediate locations on the grating of operating platforms. See

Exhibits A and D, Figures 7 through 9. There are several reasons for this exercise of discretion. 

The gratings used on operating platforms have been manufactured for years with these 

intermediate brackets being directly welded to the gratings, and FRA is not aware of any safety 

hazards arising from this design. Furthermore, due to the high quality of factory welds, a 

mechanical fastener would add little or no structural strength to the attachment. In addition, this 

type of weldment will be permitted only on intermediate brackets, where less stress is being 

placed on the attachment. All platform attachments at end supports will be required to be 

mechanically fastened. See Exhibits A and C, Figures 6 and 6A. Moreover, the only field repair 

that will be permitted on intermediate brackets will be replacement of the grating assembly with 

a factory-made assembly or application of mechanical fasteners. See Exhibits A and D, Figures 

7 through 9. 

The guidance contained in this bulletin applies only to operating platforms on tank cars without 

underframes and is not intended to apply to safety appliances at any other location on a car. 

See Exhibits: A through I. 
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Exhibit A: 

 
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Exhibit B: 
Federal Railroad Administration 

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Exhibit C: 
Motive Power and Equipment Compliance Manual 

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Exhibit D: 
Federal Railroad Administration 

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Exhibit E: 
Motive Power and Equipment Compliance Manual 

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Exhibit F: 
Federal Railroad Administration 

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Exhibit G: 
Motive Power and Equipment Compliance Manual 

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Exhibit H: 
Federal Railroad Administration 

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Exhibit I: 
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Chapter 11

Brake System Safety Standards for Freight & 

Other Non-Passenger Trains & Equipment; 

End-of-Train Devices 

Part 232 

Introduction

The Power Brake Regulations were revised and issued January 17, 2001, with an effective date 

of April 1, 2001. In order to give the railroads and contractors sufficient time to develop and 

provide the required training to their employees, the implementation date for the majority of the 

provisions was April 4, 2004. 

The following guidelines and interpretations have been developed to aid Federal and State 

Inspector(s) conducting inspections for compliance with part 232. It is important that agency 

interpretations and policies be adhered to by every Inspector when conducting these inspections, 

so that uniformity of compliance activity is achieved. Reports of power brake inspections are 

made on the Motive Power and Equipment (MP&E) Inspection Report F6180.96. Violations are 

to be submitted on the MP&E Violation Report – FRA F6180.109. 

Strict liability applies when a railroad uses vehicle (car, locomotive, tender, or similar vehicle) 

or allows it to be used a with a defective power brake condition, and appropriate enforcement 

action must be taken unless the vehicle has been properly tagged and is being moved to the 

nearest repair location for the purpose of repair. In order to establish a violation of part 232, 

FRA must prove that the vehicle was “in use” or “allowed to be used” with a defective condition. 

Thus, evidence that the equipment was in use or allowed to be used with a defective power brake 

condition is always necessary to support a violation. Additionally, FRA considers a vehicle “in 

use” or allowed to be used as long as the railroad has or should have completed its required tests 

and inspections and the vehicle is deemed ready for service, prior to any movement or the actual 

departure. Defects found at this time are subject to potential civil penalties. Therefore, the 

Inspector is not required to wait for a vehicle with a defective power brake to depart or engage in 

an actual “haul” in order to assess a violation. In accordance with the above “in use” 

interpretation, the violation report must establish that the railroad had completed or should have 

completed all necessary inspections capable of discovering the defective condition(s). 

Therefore, evidence must be included in the violation report that establishes the Inspector’s basis 

for this finding. Be as specific as possible. Inspectors should include names of people, if they 

are available and the information that they provide is helpful in establishing “use”; however, 

remember to use judgment and discretion in exercising FRA’s enforcement authority. In some 

situations it may not be the best or appropriate approach to include such information (for 

example, it would not be appropriate to include a person’s name if doing so would reveal the 

indentity of a complainant in a complaint-based investigation). In many circumstances the best 

approach is to establish actual use or movement of the equipment. 
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Inspectors are expected to use sound judgment, along with the procedures and guidance provided 

in both this manual and the General Manual when assessing the need for appropriate 

enforcement actions regarding any non-compliance with part 232. 

In the past, questions were raised concerning the method of compiling air brake inspection data. 

Therefore, a variety of activity codes and source codes were developed for power brake 

inspection activities. There are codes that distinguish whether cars are “on-air” or “off-air” when 

inspections for air brake compliance, part 232, are performed. For the purposes of this 

discussion, “on-air” means the car has sufficient brake pipe pressure to operate the air brake 

pistons, and the car is inspected with the brakes applied. This could be either with a full service 

or an emergency brake application. “Off-air” means the car is inspected without the brakes 

applied. FRA Inspectors routinely examine cars that are not “on-air” to inspect for the 

securement of the brake equipment, the position of the retainers, condition of the brake pipe and 

valves, the operation of angle cocks, etc. Such inspections are included in the car count under 

the activity code for part 232. However, many functions of the brakes cannot be observed; i.e. 

piston travel limits, binding or fouling, audible air leaks, etc. 

FRA also needed to distinguish between “inbound” and “outbound” extended haul inspections, 

and there was a need to separate inspection activities of MP&E Inspectors and OP Inspectors. 

Therefore, to accomplish the above, Inspectors shall use the following activity or source codes 

for part 232 inspection activities: 

 Activity Code Inspection Activity

 232 Any car inspected for Part 232 compliance that does 

not have the brakes applied. 

 

232A Any car inspected for Part 232 compliance that has 

the brakes applied by either a service reduction or 

an emergency application, so that the functionality 

of the brakes and piston travel limits can be 

observed. 

232T Anytime a train air brake test is observed. 

232E An inspection of the End-of-Train Device is 

conducted. 

232S Monitoring a single car or repair track air brake test. 

232O OP Inspectors observing and Initial Terminal brake 

test in the cab of the locomotive only. 

232X OP Inspectors conducting inspections for 

securement of freight locomotive equipment. 
Motive Power and Equipment Compliance Manual 

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 Source Code

 Z Outbound Extended Haul train inspections. 

Inspectors are also reminded that they need to verify the number of cars inspected before 

entering the number on the inspection report. Do not rely solely upon the representation of 

railroad personnel or train consist sheets to determine how many cars are inspected. There are 

several methods Inspectors could use, including counting the cars with hand-held counters, or 

using the train consist and checking off the cars as they are inspected. 

§ 232.3 Applicability

Part 232 generally applies to all freight and other non-passenger train brake systems and 

equipment. However, subpart E – End-of-train devices, applies to both freight and passenger 

train operations. 

Circus trains are required to comply with part 232. Tourist, scenic, historic or excursion 

operations that are part of the general railroad system of transportation have to comply with the 

provisions of part 232 as it existed on May 31, 2001, prior to the effective date of the new 

regulations. The text of the regulations as they existed on May 31, 2001 is found in Appendix B 

of the new rule. 

Private cars are designed to carry passengers and are generally hauled in both freight and 

passenger trains. These types of cars may be covered by part 232 as well as the Passenger 

Equipment Safety Standards in part 238. For example, private cars will be subject to the 

maintenance and equipment standards applicable to passenger equipment, but will be covered by 

the inspection requirements contained in this part when hauled in a freight train. 

Maintenance of Way (MofW) vehicles must comply with part 232. This includes passenger 

MofW vehicles as long as they were built on or after September 21, 1945. 

§ 232.5 Definitions

This regulation contains an extensive set of definitions that are intended to clarify the meanings 

of important terms used in the text of the final rule. The text of the definitions was carefully 

worded to minimize the potential for misinterpretations. However, a few terms have elicited 

further questions that will be addressed as follows: 

Air flow indicator, AFM: As the definition states, the indicator face must display markings from 

10 cubic feet per minute (CFM) in increments of 10 CFM or less. It must also display numerals 

indicating 20, 40, 60 and 80 CFM. If an indicator is marked with numerals of 2, 4, 6, 8, 10, 12, it 

is not an indicator that can be used to qualify the brake pipe pressure of a train, in lieu of 

conducting a brake pipe leakage test. It may still be used by the engineer for the purpose of 

operating a train and it must be tested for accuracy within the prescribed time periods. 
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Brake, effective: Means a brake that is capable of producing its nominally designed retarding 

force on the train. Inspectors often find instances where only the top or bottom half of a brake 

shoe is in contact with the wheel and question whether this is an effective brake. FRA conducted 

studies with the AAR and found that this condition does not render a brake ineffective. 

Therefore it is not, and should not be considered, a defective condition. 

Off air: Means not connected to a continuous source of compressed air of at least 60 pounds per 

square inch (psi). If the automatic brake valve is drawn down below 60 psi, the train would be 

off air. 

Previously tested equipment: Means equipment that has received a Class I brake test and has not 

been off air for more than 4 hours. If equipment is charged to 60 psi and recharged every 3 

hours and 45 minutes, then the equipment would not be considered off air. 

Qualified Mechanical Inspector (QMI): The only time a QMI is required is for the inspection 

and testing requirements for extended haul trains found in § 232.213 and ECP per § 

232.607(a)(1). 

Qualified person: An Inspector should observe the performance and outcome of an individual 

conducting an inspection or test and ask appropriate questions to determine if an individual is a 

qualified person. If there are questions concerning the knowledge, skills, or ability of an 

individual, notify the Regional Specialist for further instructions on how to obtain the training 

records to determine if the training requirements have been fulfilled. The agency does not want 

Inspectors requesting training records on individuals. This should be done by the Regional 

Specialist or Headquarters Specialist. 

“Roll-by” inspection: This is only applicable for the “release of brakes” portion of the 

inspection. It does not constitute an inspection of one side of the train for the purpose of 

satisfying the requirement of inspecting both sides of the train during a brake inspection. 

Switching service: Is defined as the classification of freight cars according to commodity or 

destination; assembling of cars for train movements; changing the position of cars for purposes 

of loading, unloading, or weighing; placing of locomotives or cars for repair or storage; or 

moving of rail equipment in connection with work service that does not constitute a train 

movement. Thus, even if a train is in involved in switching, it will require a brake test, if it will 

engage in a “train movement,” as determined by FRA. The determination of whether the 

movement of cars is a “train movement” or a “switching movement” is and will be based on the 

extensive case law developed by various courts of the United States. 

FRA’s general rule of thumb as to whether a trip constitutes a “train movement” requires 5 or 

more cars coupled together that are hauled a distance of at least 1 mile without a stop to set off or 

pick up a car and not moving for the purpose of assembling or disassembling a train. However, 

FRA may consider movements of less than one 1 mile “train movements” if various 

circumstances exist. In determining whether a particular movement constitutes a “train 

movement,” FRA conducts a multi-factor analysis based upon the discussions contained in 

various court decisions on the subject. See e.g. United States v. Seaboard Air Line R.R. Co., 361 
Motive Power and Equipment Compliance Manual 

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U.S. 78 (1959); Louisville & Jeffersonville Bridge Co. v. United States, 249 U.S. 543 (1919). 

The following factors are taken into consideration by FRA: the purpose of the movement; the 

distance traveled without a stop to set out or pick up cars; the number of cars hauled; and the 

hazards associated with the particular route traveled (e.g., the existence of public or private 

crossings with or without crossing protection, the steepness of the grade, the existence of curves, 

any other conditions that minimize the locomotive engineer’s sight distance and any other 

conditions that may create a greater need for power brakes during the movement). The existence 

of any of these hazards would tend to weigh towards the finding of a “train movement,” since 

these are the types of hazards against which the power brake provisions on the Federal rail safety 

laws were designed to give protection. 

Transfer train: May pick-up and set-out cars while enroute. Any cars picked-up will have to 

receive at a minimum, a transfer train brake test. However, this does not start a new 20-mile 

transfer train unless a transfer train brake test is performed on the entire train at that particular 

location. Yes, a train could travel 100 miles as a transfer train, if a transfer train brake test is 

performed at every 20-mile segment of the trip. 

Unit or Cycle train: Must remain coupled as a consist and continuously operates from location A 

to location B and back to location A. FRA will not take exception if the train is separated for 

the purpose of loading/unloading, as long as the cars are not off-air for more than four (4) hours 

and the consist remains in the original order. A block of cars can be added and removed as long 

as the cars added are given a Class I brake test before the block of cars are added to the train. 

§ 232.9 Responsibility for Compliance

This section contains the “use” or “haul” language as previously discussed. It basically states 

that any train, railroad car, or locomotive covered by this part will be considered “in use” prior to 

departure, but after it receives or should have received the necessary tests and inspections 

required for movement. FRA will not necessarily wait for a piece of equipment with a power 

brake defect to be hauled before issuing a violation report and recommending a civil penalty. 

FRA believes that this approach increases FRA’s ability to prevent the movement of defective 

equipment that creates a potential safety hazard to both the public and railroad employees. If 

Inspectors rely on the “in use” provision, the violation report must establish that the railroad has 

completed or should have completed all necessary inspections capable of discovering the 

defective condition(s). Therefore, evidence must be included in the violation report that 

establishes the Inspector’s basis for this finding. Be as specific and thorough as possible. 

Remember, this is added enforcement flexibility and may not be the best approach in certain 

situations. 

At interchange, a railroad can refuse to accept vehicle with a non-complying condition. In this 

scenario, if a railroad elects to receive the defective vehicle and the vehicle is not properly 

tagged, both the offering railroad and the receiving railroad can be held liable. 

Paragraph (c) states that any “person” that performs any function or task required by this part 

will be deemed to have consented to FRA inspection of the person’s operation to the extent 

necessary to ensure that the function or task is being performed in accordance with the 
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requirements of this part. This provision is intended to put railroads, contractors and 

manufacturers that elect to perform tasks required by this part on notice that they are consenting 

to FRA’s inspection for rail safety purposes of that portion of their operation that is performing 

the function or task required by this part. In most cases, this function or task involves a 

contractor’s performance of certain required brake inspections or the performance of specified 

maintenance on cars, such as conducting single car or repair track tests on behalf of a railroad. 

FRA believes that if a person is going to perform a task required by this part, FRA must have the 

ability to view the performance of such a task to ensure that it is conducted in compliance with 

federal regulations. This is supported by 49 U.S.C. § 20107, which requires that FRA be 

allowed access to a railroad’s property at a reasonable time and a reasonable way to conduct 

inspections. If an Inspector encounters a location that prohibits access on the property to 

perform an inspection, the Regional Specialist should be immediately notified, who will then 

contact Headquarters for further instructions. 

§ 232.11 Penalties

This section identifies the penalties that may be imposed upon a person, including a railroad or 

an independent contractor providing goods or services to a railroad, that violates any requirement 

of this part. While the responsibility for non-complying equipment is usually applied to the 

hauling railroad, if a contractor is performing one of the required inspections and/or tests, the 

responsibility can be placed on either the contractor or the railroad, or both. The Inspector 

should consult with the Regional Specialist to determine where the enforcement action should be 

directed. The schedule of civil penalties is listed in Appendix A of this rule. 

§ 232.15 Movement of Defective Equipment

This section contains the provision regarding the movement of equipment with defective brakes 

without civil penalty liability. 

Paragraph (a) of this section contains various parameters which must exist in order for a railroad 

to be permitted to haul a piece of equipment with defective brakes for repairs without civil 

penalty liability. The rule contains language in the provisions that accurately reflect the 

language contained in the existing statutory provisions pertaining to the movement of equipment 

with defective brakes. 

The statutory provisions contained in 49 U.S.C. § 20303 (previously 45 U.S.C. § 13) govern the 

movement of equipment with defective or insecure safety appliances, which includes power 

brakes. This only allows the railroad to move the defective equipment from the place where the 

defect is first discovered to the nearest location where the necessary repairs can be made. This 

movement can either be on the railroad where the defect is first discovered or on the line of the 

connecting railroad, only if the connecting railroad has elected to accept the non-complying 

equipment and the point of repair on the connecting railroad’s line, where the equipment will be 

repaired, is no farther than the point where the repairs could have been made on the line where 

the equipment was first found to be defective. A railroad can refuse to accept a defective car at 

interchange. Until the receiving railroad accepts the car by either moving it or otherwise 

exercising control over it, it is not liable for civil penalties nor is it required to make any repairs. 
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It should be noted that the delivering railroad remains liable for each defective car it tenders in 

interchange unless the car is properly tagged. 

A car or locomotive with a defective air brake condition cannot be tagged and moved from a 

location that has the capability to make the necessary repairs. Nor can a car or locomotive with a 

defective brake condition be tagged and moved in a train that receives a Class I brake test on the 

entire train, irrespective of whether it is at a location where repairs cannot be made. 

The statutory provision contained in 49 U.S.C. § 20303 is an affirmative defense to be 

established by the railroad. There are 7 elements which must be established: 

1. The car was properly equipped with power brakes. 

2. The car became defective while being used by the railroad on its line. 

3. The railroad discovered the defect prior to the movement. 

4. The movement was from the place where the defect was first discovered. 

5. Repairs could not be made at the location where the defect was first discovered. 

6. Movement was necessary to make the necessary repairs 

7. The car moved only to the nearest available point where the necessary repairs could be 

made. 

Paragraph (b) of this section contains the specific requirements regarding the tagging of 

equipment found with defective brake components. The requirements contained in this 

paragraph are very similar to the tagging requirements contained in part 215, regarding the 

movement of equipment not in compliance with the Freight Car Safety Standards. This 

paragraph also permits the use of an automated tracking system in lieu of directly tagging the 

equipment if the automated system is approved for use by FRA. If and when a procedure is 

approved, Inspectors will be notified by a Technical Bulletin issued by Headquarters. Any 

automated tracking system approved for use by FRA must be capable of being reviewed and 

monitored by FRA at any time (i.e. 24 hours a day, 7 days a week). There must be security 

features specific to monitoring and tracking defective equipment with which the system is 

outfitted. There also must be procedures in place in the event the electronic tracking system 

were to experience a breakdown or malfunction and become unavailable to railroad personnel. 

As both the statute and the regulation permit the interchange of defective equipment, in specified 

circumstances, FRA finds it unrealistic to believe that a railroad will not take advantage of this 

flexibility. Therefore, there would have to be a method on how a foreign railroad that receives 

equipment at interchange will have knowledge that it is receiving defective equipment without 

access to the railroad’s automated tracking system at the interchange location. Also, how it will 

handle defective equipment being delivered to it in interchange by another railroad would have 

to be addressed. There are no regulations establishing tagging requirements for safety appliance 

defects. 

Paragraph (c) restricts the movement of a vehicle with defective brakes for the purpose of 

unloading or purging, unless it is necessary for the safe repair of the car. Therefore, cars with 

defective brakes cannot be moved to a location to be loaded or unloaded until the defective 

condition is corrected, unless the location is the location where the repairs will be made. 
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Paragraph (e) contains the guidelines for train placement. If a freight car or locomotive has 

inoperative brakes, it cannot be placed as the rear car of a train. This provision would apply to 

multi-unit articulated equipment if the rear control valve is cut-out. Additionally, there cannot be 

two or more freight cars consecutively placed in the same train if both cars either have 

inoperative brakes or are not equipped power brakes. Finally, a multi-unit articulated equipment 

with a defective brake cannot be placed in a train if more than 2consecutive individual control 

valves are cut-out. 

Paragraph (f) contains general guidelines that FRA will consider when determining whether a 

location is one which should be considered a location where brake system repairs must be made. 

FRA expects a railroad to consider the guidance contained in this paragraph when making its 

decisions on where equipment containing brake defects will be repaired. The guidance contained 

in this paragraph is based upon, and consistent with, the voluminous case law which exists that 

establishes the guiding principles for determining whether a location constitutes a location where 

the necessary repairs can be made, and whether a location is the nearest location where such 

repairs can be effectuated. These guidelines are equally applicable to determining such repair 

locations for all safety appliance defects. The guidelines must be applied on a case-by-case basis 

to determine if the railroad acted in good faith in moving defective equipment. The following 

guidelines should be used to determine if a location should be considered a repair location: 

 Whether the location has an operative repair track or repair shop. 

 Whether the location is a place where the railroad performs mechanical repairs other than 

safety appliance and/or power brake repairs. 

 Whether repair truck(s) are permanently stationed there or whether they come from 

another location. 

 Whether the location is a place where a mobile repair truck is used on a regular basis. 

These guidelines provide the outlines for determining what is a repair location, but Inspectors 

will often need to provide details to support their conclusions. For instance, Inspectors must 

fully explain trackage availability in the narrative if the location is a place where a mobile repair 

truck is used. Similarly, if the location is being identified as a mobile repair truck location, they 

should explain where nearest major facility is in relation to the mobile repair truck location (i.e. 

repair shop or location where mobile repair truck is permanently stationed or originates). 

Additionally, they should discuss the type of repair facility, including what types of repairs are 

made at the location and any other pertinent information. 

While FRA acknowledges that not every location where a mobile repair truck is capable of 

making repairs should be considered a repair location, FRA firmly believes that locations where 

repair trucks are used in virtually the same manner as a fixed facility should be considered when 

determining whether the location is capable of making the necessary repairs. 

In determining whether a location, noted above, is capable of making a particular repair, the 

following factors must also be considered: 

 The accessibility of the location to persons responsible for making repairs. 
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 The presence of hazardous conditions that affect the ability to safely make repairs of the 

type needed at the location. 

 The nature of the repair necessary to bring the car into compliance. 

 The need for railroads to have in place an effective means to ensure the safe and timely 

repair of equipment. 

 The relevant weather conditions at the location that affect accessibility or create 

hazardous conditions. 

 A location need not have the ability to effectuate every type of safety appliance or power 

brake repair in order to be considered a location where some safety appliance or power 

brake repairs can be made. 

 A location need not be staffed continuously in order to be considered a location where 

safety appliance repairs can be performed. 

 The congestion of work at a location shall not be considered. 

In addition to considering the factors noted above for determining if the location is the nearest 

location where the necessary repairs can be made, Inspectors must consider distance to the 

location -- although this is a key factor, it should not be the determining factor. This must be 

considered in conjunction with all the factors previously noted as well as the following safety 

considerations: 

 The safety of the employees responsible for getting the equipment to orfrom a particular 

location; and 

 The safety hazards involved in moving the equipment in the direction of travel necessary 

to get it to a particular location. 

Inspectors need to address the items discussed in Paragraph (f) in the written narrative if civil 

penalties are being pursued. 

Paragraph (g) provides a method by which a railroad may designate locations where various 

brake system repairs will be conducted. See Appendix B of the Compliance Manual for the 

railroads that have designated locations where brake system repairs will be conducted. This not 

only provides the railroad name, but the list of locations designated by the railroad. 

§ 232.17 Special approval process

This section contains the procedures to be followed when seeking to obtain FRA approval of a 

pre-revenue service acceptance plan under §232.505 for completely new brake system 

technologies or major upgrades to existing systems or when seeking approval of an alternative to 

the test standard incorporated in §§232.305 or 232.307. 

§ 232.103 General requirements for all train brake systems

This section contains general requirements that are applicable to all freight and non-passenger 

train brake systems. This section specifically includes certain basic train brake system practices 

and procedures that form the foundation for the safe operation of all types of trains. 
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Paragraph (d) requires 100% operative brakes where a Class I brake test is required to be 

performed. This applies only when the Class I test is performed on the entire train. It does not 

apply at locations where a railroad elects to perform a Class I brake test on cars that are pickedup en route and added to an existing through-train. Therefore, it is permissible to conduct a 

Class I brake test on cars picked-up en route and move a car with defective brakes from that 

location under the provisions of §232.15 – Movement of defective equipment. Although FRA 

recognizes that the 100% requirement may be somewhat burdensome for some railroads at 

certain locations, FRA believes that the number of locations involved is relatively low and 

should be formally handled on a case-by-case basis through the existing waiver process. 

Railroads applying for such waivers must be able to establish a true need for the exception and 

must be willing to provide alternative operating procedures that ensure the safety of the trains 

being operated from those locations. 

Paragraph (g) requires the piston travel limits be indicated by either a stencil, sticker, or badge 

plate on all cars except for cars equipped with nominal 12-inch stroke (81⁄2 and 10-inch 

diameter) brake cylinders. Note: there are some applications of 12 x 10-inch brake cylinders that 

have a 5-inch range. For these applications, a stencil, sticker or badge plate would have to 

convey that information. 

Furthermore, pursuant to FRA’s conditional approval of a waiver request related to minimum 

piston travel requirements, see docket number FRA-2004-19402, these cars shall have the 

empty/load valve tested, if so equipped, as prescribed in AAR Standard S-486-04, Sections 4.6.1 

through 4.6.5, anytime a single car test is performed on the car, irrespective of whether the valve 

has been changed or not. Please note that this test is not required if the car is loaded, since the 

test can only be performed when the car is empty. 

Often there are inquiries concerning the proper method for measuring brake cylinder piston 

travel on freight cars. In order to achieve consistent compliance, the following procedure will be 

used to measure piston travel. The actual movement of the piston is the distance that must be 

measured. To determine this measurement, the longstanding practice of measuring piston travel 

from the front of the brake cylinder (non-pressure head) to the grease mark on the hollow rod 

will be used. If a grease mark is not evident, a line scribed on the hollow rod would suffice (see 

Figure 1). If there is confusion as to what the piston travel should be on a particular car, refer to 

either the badge plate or stenciling located in a conspicuous place near the brake cylinder. 
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Figure 1: Method of measuring the piston travel 

Paragraph (h) requires that all cars placed into service on or after April 1, 2004, be designed so 

that an Inspector does not have to place himself or herself on, under or between components of 

the equipment to observe brake application or release. This paragraph also allows railroads the 

flexibility of using a reliable indicator in place of requiring direct observation of the brake 

application or piston travel because the designs of some freight car brake systems make direct 

observation extremely difficult unless the Inspector places himself or herself underneath the 

equipment. Although the rule permits the use of an indicator for purposes of determining piston 

travel, the individual inspecting such equipment would be required to inspect all components of 

the brake system for proper operation. 

Paragraph (n) addresses the securement of unattended equipment by means of applying 

handbrakes, venting brake pipe to zero and leaving the angle cock open on one end of a cut of 

car(s) and requiring the railroad to develop and implement procedures to verify that the 

equipment is secure. Unattended equipment is equipment left standing and unmanned in such a 

manner that the brake system of the equipment cannot be readily controlled by a qualified 

person. When assessing this situation for compliance, the Inspector should take into account 

following factors: 

 Can a person take corrective action if the equipment should start to roll away? 

 Can the individual readily mount the car and apply the handbrake or can the individual 

safely open an angle cock should the equipment start to roll away? 

 Can the individual readily mount the locomotive and either apply the handbrake or 

operate the brake handles or emergency brake valve to stop the unexpected movement? 

 Is the qualified person focused on the situation? For example, if the individual is eating 

lunch or in the bathroom, full attention is not being given to the equipment. If the 

individual is in a crew room or talking on the phone, full attention is not being given to 

the equipment. 
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If an engineer and crew gets off of their train to watch a passing train, and remains in close 

proximity of their locomotive consist, handbrakes would not have to be applied on the 

locomotives, as long as someone is close enough to readily mount the locomotive and apply an 

emergency brake or handbrake, should the locomotives or train start to roll away. If the engineer 

and crew got off their train and positioned themselves between the passing train and their train, 

handbrakes would have to be applied, as their train would be considered unattended. 

FRA will not take exception to a train crew cutting away from a cut of cars, initiating an 

emergency brake application on the cut of cars, and then closing the angle cock for the sole 

purpose of taking the locomotives to the opposite end of the cut of cars to either: (1) couple the 

locomotives to the cars; or (2) open the angle cock at the other end and leave the angle cock open 

and vented to atmosphere as required under 49 CFR § 232.103(n)(2). However, if the 

locomotive cuts away from the cars and closes the angle cock without going “directly” to the 

other end to either open the angle cock or couple the locomotives to the cars, the railroad would 

be in violation of 49 CFR § 232.103(n)(2). The emphasis is “directly” because even though it 

may be the train crew’s intent to go “directly” to the opposite end of the cars to take the 

appropriate action, if a train dispatcher, or whomever, directs the crew to perform another job 

task before they “directly” go to the opposite end of the cars, a violation is committed. It is only 

with the understanding that the train crew goes “directly” to the other end of the cars to take the 

appropriate action that FRA will permit this type of activity. 

The term “Yard Limits” as used in the context of this paragraph for the securement of equipment 

means: 

 A system of tracks, other than main tracks and sidings, used for classifying cars, making 

up and inspecting trains, and/or storing cars. 

See 49 CFR § 232.7. The securement requirements contained in this rule do not apply to 

distributed power locomotives when they are placed in a train. However, if locomotives are left 

in a yard or siding waiting to be used as distributed power and they are unattended, appropriate 

handbrakes have to be applied. 

A locomotive consist is 1 or more locomotives coupled together. They do not have to have the 

electrical cables connected, nor do they have to have the air hoses coupled. As long as the 

locomotives are coupled together via the coupler, it is a locomotive consist. 

Locomotives located in a locomotive servicing area under the control of mechanical forces do 

not have to have handbrakes applied while mechanical personnel are preparing them for service. 

However, once the mechanical people are finished and/or have placed them on “ready tracks” for 

the train crew or hostler, appropriate handbrakes would have to be applied. Also, train crews 

have to apply appropriate handbrakes on locomotives they leave in servicing areas, unless 

mechanical personnel are in place to take immediate control of the locomotives. Anytime 

mechanical forces are not on duty at a service track location, appropriate handbrakes have to be 

applied. 
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In yard environments where there is active switching activity, there must be a sufficient number 

of cars secured on both ends of a yard track. The unattended, unattached railcars between the 

secured ends do not have to be secured. In sidings along the right-of-way, cars must be secured 

to prevent any car, or group of cars, from rolling out of the siding. 

Paragraph (n)(1) includes a performance-based requirement that a sufficient number of hand 

brakes be applied to hold the equipment and that railroads have to develop and implement a 

process or procedure to verify that the applied handbrakes will sufficiently hold the equipment 

when the air brakes are released. This requires a railroad to develop appropriate operating rules 

to verify the sufficiency of the handbrakes applied, which can be tailored to the specific territory 

and equipment operated by the railroad. This can be as elaborate as the use of a sophisticated 

matrix or some type of “set calculations” that specify exactly how many handbrakes have to be 

applied on specific numbers of cars; or it can be as simple as having the engineer release the 

pneumatic brakes after the handbrakes have been applied, to determine if the equipment is 

secure. To simply have instructions that state “a sufficient number of handbrakes have to be 

applied” does not satisfy the intent of the regulation, unless there is the provision that the 

pneumatic brake has to be released to determine the equipment is secure. 

 

§ 232.105 General requirements for locomotives

This section contains general provisions related to locomotives. It does not include provisions 

related to the inspection and maintenance of the locomotive braking systems, as these 

requirements are adequately addressed in Part 229. The exception is the locomotive handbrake 

or parking brake, which has to be inspected and necessary repairs made as often as service 

requires, but no less frequently than every 368 days. The date of the last inspection must be 

entered on Form FRA F6180-49A or suitably stenciled or tagged on the locomotive. Transport 

Canada’s Cab Form 22, Item 8(a) includes this same information. The information in Item 8(a) 

of Transport Canada Cab Form 22 satisfies FRA’s requirements. 

§ 232.107 Air source requirements

This section contains requirements directed at ensuring that freight brake systems are devoid, to 

the maximum extent practical, of water and other contaminants which could conceivably 

deteriorate components of the brake system and, thus, negatively impact the ability of the brake 

system to function as intended. 

Paragraph (a) requires railroads to adopt and comply with a plan to monitor all yard air sources 

to ensure that the yard air sources operate as intended, are in proper condition, and do not 

introduce contaminants into the brake system of freight equipment. FRA intends to make clear 

that the inspections required under this paragraph are to be thorough inspections of the entire 

yard air source. This inspection would include not only the compressors, but all piping, hoses, 

valves, and any other component or part of the yard air source to ensure it is in proper condition 

and operates as intended. This also means that corrective action must be taken on any 

component that does not operate as intended, such as replacing desiccant in air dryers, and/or 

tightening pipe connections in the yard to stop air leaks, and replace defective valves and hoses. 
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These inspection requirements apply to any air compressor that is capable of introducing 

contaminants into the brake pipe of a car or locomotive. Shop compressors, rental compressors 

and portable air compressors will have to receive the periodic inspections and repairs, along with 

a written plan and records. 

Railroads must maintain records (either electronically or in writing) related to yard air 

monitoring plans. FRA believes that these records are necessary to ensure that railroads are 

properly conducting the required inspections and are taking timely and appropriate remedial 

action when a problem air source is detected. 

The monitoring plans apply to any yard air source, either a stationary or portable air compressor, 

that is used to introduce compressed air into cars and/or locomotives. 

While this rule does not contain specific requirements regarding the use of air dryers on either 

locomotives or yard air sources, it is FRA’s position that air dryers must be properly maintained. 

Therefore, if an Inspector finds an air dryer that is inoperative or has contaminated desiccant, 

appropriate enforcement action should be taken. For locomotives, §232.105(a) “safe and 

suitable”, should be cited. If the defection condition is found on a yard air source, the Inspector 

should review the air monitoring plans and records for compliance. 

Paragraph (c) retains the proposed requirement that a railroad adopt and comply with detailed 

written operating procedures tailored to the equipment and territory of the railroad to promote 

safe train operations during cold weather situations. 

§ 232.109 Dynamic brake requirements

Paragraph (a) requires that a locomotive engineer be informed of the operational status of the 

dynamic brakes on the locomotives the engineer will be required to operate. This information is 

to be provided to the locomotive engineer at a train’s initial terminal and at other locations where 

a locomotive engineer first begins operation of a train. While it allows railroads to provide a 

locomotive engineer with the required information by any means they deem appropriate, the rule 

is clear that a written or electronic record of the information provided shall be maintained in the 

cab of the controlling locomotive. This will ensure that relief or other oncoming engineers will 

have the information that was provided to the previous locomotive engineer. The information 

required has to inform the engineer of exactly how many units have operating dynamic brakes. 

This is only required on railroads that use or operate locomotives with dynamic brakes. 

Paragraph (b) requires that a locomotive with inoperative dynamic brakes must be repaired 

within 30 days of being found inoperative or at the locomotive’s next periodic inspection, 

whichever occurs first. If the locomotive is not in a shop that can effectuate the dynamic brake 

repairs at either the 30-day time period or the locomotive’s periodic inspection, the locomotive 

must be tagged and moved as prescribed in § 232.15, as this is a power brake defect. It cannot 

be tagged and moved under the provisions of § 229.9. If the locomotive happens to be on a 

foreign railroad when either the 30-day time period or periodic inspection is due and the 

movement would require the locomotive to pass several repair locations before it could be 
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returned to the owning railroad, the foreign railroad must make repairs or ask FRA for 

permission to move the locomotive past the repair points. 

Paragraph (c) contains the requirements related to the tagging of a locomotive found with 

inoperative dynamic brakes. This should be done when the defective condition is initially 

identified. Since the locomotive engineer generally discovers this defect, he or she should 

properly fill out the tag and apply it to the locomotive. 

Paragraph (e) contains the provision permitting a railroad to declare a locomotive’s dynamic 

brakes “deactivated” if the following requirements are met: (1) the locomotive is clearly marked 

with the words “dynamic brake deactivated” in a conspicuous location in the cab of the 

locomotive; and (2) the railroad has taken appropriate action to ensure that the deactivated 

locomotive is incapable of utilizing dynamic braking effort to retard or control train speed. It 

should be noted that FRA intends for this provision to be a permanent application and not used 

as a solution to circumvent or delay the repair of a defective dynamic brake. 

The provisions of § 232.109 are intended to apply to those trains that utilize their dynamic brakes 

during the train movement. Thus, if the involved run is one on which dynamic brakes are 

usually employed, then all of the requirements of § 232.109 would apply. Similarly, if the train 

operation is one where dynamic brakes are not used, then the provisions like §§ 232.109(f) and 

(g) would not be applicable. Sections 232.109(f) and (g) do not apply to trains used in helper 

service. 

Q: Is it permissible to depart a location where a train originates or a terminal where locomotives 

can be rearranged, without the controlling unit having dynamic brakes? 

A: Yes, but only in two (2) limited circumstances: 

1. The locomotive consist is not intended to have dynamic brakes used while in transit (if the 

run generally requires or usually utilizes dynamic brakes, then this would not apply); 

2. The controlling locomotive is capable of controlling the dynamic brakes on trailing units and

is equipped with either an accelerometer or a dynamic brake indicator. 

Q: If a train departs location A with all of the dynamic brakes working and prior to arrival at an 

intermediate terminal (crew change point), the dynamic brake fails on the lead unit, does the unit 

have to be swapped or repaired prior to departure from the crew change point? 

A: If the unit is equipped as stated above, NO. If not so equipped, then the unit needs to be 

switched out where it is safe to do so, this may or may not be the crew change point depending 

on the track availability. 

Q: If a train consist that departed an initial terminal with working dynamic brakes and arrives at 

its destination with defective dynamic brakes, can it depart if there are no other locomotives 

available? 
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A: Only if the controlling locomotive is capable of controlling the dynamic brakes on trailing 

units and is equipped with either an accelerometer or a dynamic brake indicator. If none of the 

units had an operative dynamic brake, FRA would still require an accelerometer, if this train 

operated over a route that required the use of dynamic brakes. 

§ 232.111 Train information handling 

This section contains the requirements regarding the handling of train information. This 

information has to be updated whenever a new train crew takes charge of a train. This 

information is applicable to trains receiving a transfer air brake test and operating as transfer 

train movement. However, this information would not have to be on a transfer move made 

within the confines of a yard, as defined in 49 CFR § 232.7. 

§ 232.203 Training requirements 

This section contains the general training requirements for railroad employees and contractor 

employees that perform the inspections and test required by this part. Each railroad is 

responsible for training its employees and maintaining the required records. Likewise, the 

contractor is responsible for providing appropriate training to its employees and maintaining the 

required records and information. However, this does not relieve the railroad from potential civil 

penalties for, e.g., failure to perform a proper Class I brake test, if the employees of a contractor 

are found not to be qualified to perform the task for which they are assigned responsibility. Both 

the railroad and the contractor would remain liable for potential civil penalties if the employees 

used to perform a particular task were not properly trained and qualified in accordance with the 

training requirements contained in this rule. 

For purposes of this section, a “contractor” is defined as a person under contract with a railroad 

or car owner, or an employee of a person or company under contract with a railroad or a car 

owner. 

The training that an employee is required to receive need only address the specific skills and 

knowledge related to the tasks that the person will be required to perform under this part. Thus, 

a railroad or contractor may tailor its training programs to the needs of each of its employees 

based on the tasks that each of its employees will be required to perform. If an individual never 

performs a single car test, the railroad would not have to train for this task. If the railroad never 

performs a Class II brake test, the railroad would not have to train for Class II brake inspections. 

Training consists of both classroom and “hands-on” instruction. FRA will accept either the 

traditional classroom setting with an instructor instructing the students, or an interactive 

computer-based training (CBT). For the CBT to be accepted, it must be interactive with 

questions and problem solving activities embedded into the program. It cannot be a computer 

program that reads information to people or displays text that must be read by the individual 

without methods to access the individual’s progress. FRA will not accept videos or printed 

material as the only medium for training. There must be some form of interaction with the 
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person being trained. Each person must be tested on the knowledge received from such training 

and the test scores must be documented. 

The “hands-on” portion of the training can be a structured, formal exercise monitored by an 

individual, or structured efficiency tests can be used, provided such testing is properly 

documented and covers the necessary tasks to ensure retention of the knowledge and skills 

required to perform the employee’s duties required by this part. Either method must be properly 

documented. 

The rule requires that refresher training be periodically provided at least once every three years. 

The refresher training has to consist of both classroom and “hands-on” training. FRA does not 

intend for such training to be as lengthy or as formal as the initial training originally provided, 

but believes that training should re-emphasize key elements of various tasks and focus on items 

or task that have been identified as being problematic or of poor quality by the railroad, 

contractor, or its employees through the periodic assessment of the training program. 

FRA believes that in order for a supervisor to properly exercise oversight of an employee’s work, 

the supervisor must be properly trained and qualified to perform the tasks for which they have 

oversight responsibilities. Therefore, supervisors have to receive some level of training that has 

to be documented. 

Paragraph (e) requires that each railroad or contractor adopt and comply with a plan to 

periodically assess the effectiveness of its training program. Although FRA agrees that a formal 

audit process may not be necessary, FRA continues to believe that railroads and contractors 

should periodically assess the effectiveness of their training programs. However, rather than 

require a formal internal audit, FRA believes that periodic assessments may be conducted 

through a number of different means and each railroad or contractor may have a need to conduct 

the assessment in a different manner. The use of efficiency tests or periodic review of employee 

performance could be methods for conducting such reviews. FRA agrees that many railroads, 

due to their small size, are capable of assessing the quality of the training their employees 

receive by conducting periodic supervisory spot checks or efficiency tests of their employees’ 

performance. However, FRA continues to believe that on larger railroads the periodic 

assessment of a training program should involve all segments of the workforce involved in the 

training. 

§ 232.205 Class I brake test – initial terminal inspection 

This section describes the circumstances that mandate the performance of a Class I brake test and 

outlines the tasks that must be performed when performing this inspection. Basically, a Class I 

brake test is the functional equivalent to the “initial terminal brake inspection” of the old rule. 

A Class I brake test is required at locations where more than one “solid block of cars” is added to 

or removed from a train. It should be noted that the rule permits both the addition and the 

removal of a “solid block of cars” at a location without requiring the performance of a Class I 

brake test on the entire train. However, depending on the make-up of the block of cars, certain 

inspections will have to be performed on that block of cars at the location where it is added to the 
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train. A railroad can add a single block of cars to a train that is composed of cars from numerous 

different trains, as long as the railroad assembles the cars into one block and performs a Class I 

test (or at least a Class II test) on the solid block of cars before adding the block to the train. 

Remember, this chapter of the manual only addresses the brake test requirements. Anytime cars 

are added to a train, a pre-departure inspection (part 215) must be performed on the cars. 

When a through-train arrives at a location and splits into multiple sections, the railroad can only 

designate one of the sections as being the continuing train. The other sections of the train would 

require applicable air brake tests, depending on whether they are added as a solid block of cars to 

another through-train and have not been off air for more than four (4) hours, or they are part of 

a new train. If the railroad adds a locomotive to one of the sections, FRA considers this to be a 

new train, thereby requiring at a minimum a transfer brake test or a Class I air brake test. If the 

section added to a train is being made-up at that location, then the cars would have to receive the 

same test as the train that is being built. This would be the originating point of this type of train. 

Paragraph (a)(3) permits trains to remain disconnected from a source of compressed air (“off 

air”) for four (4) hours without triggering the requirement to perform a Class I brake test. This 

would permit a railroad to recharge a train before four (4) hours elapse, so the train would retain 

its on-air status. This could be accomplished by either using a locomotive or yard air. 

Paragraph (a)(5) permits trains received in interchange to have a previously tested solid block of 

cars added to the train without requiring the performance of a Class I brake test. Previouslytested means that the cars had to have received a Class I brake test and have not been off air for 

more than four (4) hours. 

Railroads are permitted to remove defective equipment at any location, at any time, without 

triggering the requirement to perform a Class I brake test on the entire train. This also includes 

the location where the Class I test is performed. If the inspection reveals a defective car, the 

regulations do not require that another Class I test be performed after the car is removed from the 

train. 

The rule permits using an end-of-train device (EOT) to verify rear car brake pipe pressure during 

a Class I brake test, provided the reading of the rear car air pressure is from the controlling or 

hauling locomotive of the train. Under no circumstances may the rear car brake pipe pressure be 

read from a remote highway vehicle, another locomotive not attached to the train, or from any 

other location such as a remote unit installed in an office or shop. 

Handheld gauges that are used to verify the rear car brake pipe pressure are required to be 

accurate. That said, there are no Federal requirements that they be calibrated on a periodic basis. 

FRA expects a railroad to have some method in place to ensure their accuracy. This applies to 

all handheld gauges used for any and all brake tests. 

At a minimum, the inspector for the railroad must observe both sides of the equipment sometime 

during the inspection process. FRA continues to believe that both sides of the equipment must 

be observed sometime after the occurrence of activities that have the likelihood of compromising 
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the integrity of the brake components of the equipment, such as: hump switching, multiple 

switching, loading, or unloading. 

The rule requires that an adequate inspection of the brake components be conducted on both 

sides of the equipment sometime during the inspection process. This can occur before the brake 

pipe is charged and before hoses are connected. Both sides of the equipment do not have to be 

inspected while the brakes are applied. However, one side of the equipment must be inspected 

while the brakes are applied and the piston travel on each car must be inspected while the brakes 

are applied, which could require the individual conducting the inspection to cross the car to 

observe the piston travel. If an Inspector observes a railroad employee conducting the brake 

application portion of the inspection, and some of the pistons are mounted on the opposite side of 

the equipment and no attempt is made to cross over the equipment to observe the piston travel, 

then appropriate enforcement action (either an exception or violation based on the extent of noncompliance) should be considered for a “partial failure to inspect.” Similarly, if an inspection is 

being conducted from a vehicle, then the railroad employee should be observed getting out of the 

vehicle to observe the piston travel on truck mounted brake arrangement unless an indicator is 

plainly visible from the vehicle. 

The presence of numerous power brake defects can be used as proof of a railroad’s failure to 

perform a required brake test. However, if the only evidence offered to establish a “partial 

failure to perform” a required inspection is the presence of one (1) car with inoperative brakes, 

for which a separate recommendation for violation is sought, then it would be inappropriate to 

submit a separate violation for a “partial failure to perform” referencing the involved inspection. 

Generally, in order to proceed with a violation for both a failure to perform a required inspection 

and for the underlying defective equipment, FRA would prefer additional direct evidence that 

some portion of the inspection was not performed (i.e.: actual observation, witness statement), or 

the presence of numerous non-complying cars. Otherwise, it is FRA’s policy to only assess a 

civil penalty for either the substantive defects or a failure to perform the required inspection, not 

both. 

Similarly, the regulation requires trains to have 100% operative brakes unless being properly 

hauled for repairs. Thus, if the only evidence offered to establish less than 100% operative 

brakes is the presence of 1 or 2 cars with inoperative brakes, for which separate 

recommendations for violation are sought, then it would be inappropriate to submit a separate 

violation for the train having less than 100% operative brakes. Common sense dictates that if a 

freight car brake is inoperative or ineffective under § 232.103(f) at the initial terminal, then the 

involved train would not have 100% operative air brakes at the Class I inspection under § 

232.103(d). It is FRA’s policy not to assess multiple violations that are based solely on the same 

defective condition. However, if a high number of cars are found with inoperative brakes or if a 

pattern of non-compliance is fully established, then it may be appropriate to pursue separate 

recommendations for violation on the individual cars as well as the train for having less than 

100% operative brakes. 

Paragraph (c)(4) permits a retest on a car that has a “no set.” The brakes on a retested car must 

remain applied until the release is initiated and that the release be initiated no less than three (3) 

minutes after the application of the brakes. A car can be retested with the use of a suitable 
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device positioned at the car being retested rather than from the head of the consist or from the 

controlling locomotive, as long as the proper procedures are followed; brake pipe pressure 

charged and a 20 psi reduction made. An emergency application is not accepted. The practice of 

gradually opening the angle cock to initiate an application of brakes is not accepted. How many 

times may a railroad retest a car? As many times as they want, as long as the appropriate brake 

pipe pressures and reductions are made for each retest. 

 

Paragraph (c)(5) retains the proposed and current requirement that piston travel be adjusted 

during the performance of a Class I brake test, if it is found outside the nominal limits 

established for standard 81⁄2-inch and 10-inch diameter brake cylinder or outside the limits 

established for other types, which will be contained on a stencil, sticker, or badge plate. FRA 

modified the provision that establishes piston travel limits on cars equipped with 12-inch stroke 

(eight and one-half 81⁄2 or ten (10) inch diameter) brake cylinders. The new limit is six (6) to 

nine (9) inches. If piston travel is found to be less than six (6) inches or more than nine (9) 

inches when conducting the Class I brake test, the piston travel shall be adjusted to nominally 71⁄2 

inches. This change is based on a waiver, docket number FRA-2004-19402, which was 

conditionally granted on August 30, 2005. 

A “roll-by” inspection of the brake release is permitted, but it does not constitute an inspection of 

that side for purposes of inspecting both sides during the inspection. When conducting the “rollby” inspection, the person on the ground only has to position themselves on one side of the 

equipment. There must be communication between the person on the ground and the locomotive 

engineer, so that the engineer can be told to stop the train if there are any problems. 

Paragraph (c)(6) states that brake rigging shall be properly secured and shall not bind or foul or 

otherwise adversely affect the operation of the brake system. All types of brake rigging is 

subject to wear and/or damage that will cause brake rigging to bind and foul. The hook and eye 

arrangement is a type of brake rigging that will bind and foul when the components wear and the 

angularity is changed. 

Types of Hook and Eye Brake Rigging:

There are two (2) types of Hook and Eye brake arrangements commonly found on freight 

equipment, Rigging with a Vertical Body Lever, shown in Figure 2; and Rigging without a 

Vertical Body Lever, see Figure 3. 
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Figure2: Hook and Eye Brake Arrangement with Vertical Body Lever 

Figure 3: Hook and Eye Brake Arrangement without Vertical Body Lever 

Hook and Eye Brake Rigging Fouling Conditions:

Brake rods and levers which “foul” or interfere with brake rigging performance can render a 

brake system ineffective. 

The only real observable indication of serviceability in the field is: Piston Travel, Brake Shoe 

Wear, and Fouling. Fouling of the brake rigging will reduce brake performance to an 

unacceptable level. An alert inspector should look for signs of brake shoes ineffective when 

brakes applied, brake shoe orientation, how close the rigging is to a worn condition, and whether 

the rigging is fouling or binding. 
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Hook and Eye Brake Rigging New Car Condition vs. Full-Worn Condition:

A freight car which has been recently built will have brake lever angularity in the Positive (+) 

condition as shown below in Figure 4. 

 

Note that all three (3) levers have Positive (+) angularity. 

Figure 4: Brake lever angularity in the positive (+) condition 

A freight car which has been in service and has a full worn brake rigging condition will have 

brake levers with a Negative (-) angularity (see Figure 5). 

Note that all three (3) levers have Negative (-) angularity. 

Figure 5: Brake lever angularity in the negative (-) condition 

Field Inspection Criteria:

If a freight car has a Hook and Eye brake rigging arrangement, and, 

 The brake shoes are serviceable; 

 The brake rigging is not binding or fouled; 
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then the brake rigging is performing as designed and the brakes are in serviceable condition. 

If the rigging is binding or fouled, the Inspector should take a violation with the appropriate 

activity/violation code. If the brake angularity is in the negative condition, the Inspector should 

note that in the comment section of the inspection report. 

Paragraph (d) contains the provision stating that a carman alone will be considered a qualified 

person if a railroad’s collective bargaining agreement (CBA) provides that Carmen are to 

perform the inspections and tests required by this section. FRA lacks the authority to issue 

binding interpretations of CBAs, or to settle a dispute between a railroad and its employees as to 

which group of its employees is to perform what work. FRA intends to make clear, that in order 

for FRA to proceed with enforcement action under this provision, a decision from a duly 

authorized body interpreting the relevant agreement, specifically identifying the involved 

location, and adequately resolving all of the interpretative issues is necessary for FRA to 

conclude that the work belongs to a particular group of employees. FRA’s position has always 

been that the duly authorized body under the CBA must make a fact specific determination of 

any and each instance where carmen are not used specifically identifying the involved location 

and only then would a civil penalty be pursued. Without such a binding decision, FRA cannot 

make a case that the work belongs to one particular craft of workers. 

Paragraph (c)(1)(i)(D) requires that the individual conducting the leakage test must wait 45 to 60 

seconds before noting brake pipe leakage, as indicated by the brake pipe gauge in the 

locomotive, which shall not exceed 5 psi per minute. When FRA Inspectors are observing this 

test, they need to make sure that the 45 to 60 second window is followed by the person 

performing the test. 

Paragraph (c)(1)(iii) contains the calibration requirements for the air flow indicator. Noncompliance with the required periodic calibration requirements for air flow indicators is an ongoing issue. The non-compliance is often the result of either using the wrong test orifice, testing 

at the wrong brake pipe and/or main reservoir pressure, or simply not performing the calibration 

test. 

Air flow indicators used to conduct air flow method tests are required to be tested and calibrated 

every 92 days. The following guidance is written for FRA Inspectors to use when observing 

railroad personnel qualifying air flow indicators: 

1. Brake pipe (BP) leakage must be below 2 psi, in order for the air flow indicator to be 

accurately tested and calibrated. 

2. Air Flow Method (AFM) indicators shall be tested and calibrated at 90 psi BP, using the 

correct calibrated orifice. The calibrated orifice should be marked with the 90 psi BP 

pressure, serial number, and manufacturer’s part number. Verify that the correct 

calibration orifice is being used to perform the test. Since the manufactures recommend 

that test orifices should be calibrated annually, inquire about the last calibration date. If it 

is beyond one year, advise the railroad supervisor in charge that the orifice should be 
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calibrated as recommended by the manufacturer and notify the regional MP&E 

Specialist. 

o Currently, there are two (2) calibration orifice products that are available for 

testing and calibrating AFM indicators at 90 psi BP. They are: Wabtec’s Model 

#0650756-0090 and Strato’s Model # BOC500-20-70. 

o There is also a calibrated orifice supplied by Wabco, Model #0650756-0100 

which is used for BP pressure set at 100 psi. If this orifice is being used for 

testing and calibration, the feed valve setting must be set at 100 psi and then 

verify that BP is being maintained at 100 psi. 

NOTE: Strato makes six other calibrated orifices that do not comply with current 

Federal Regulations. These orifices are designed to be used at temperatures 

below 20 degree Fahrenheit, which Federal Regulations do not allow. 

3. To conduct the test, the correct test orifice must be applied to the BP hose glad hand 

(preferably the front). The angle cock is then opened to allow BP to exhaust through the 

orifice. 

4. It is very important that BP be maintained at 90 psi (or 100 psi if using the 100 psi test 

orifice) during the test. Therefore, it may be necessary to adjust the feed valve setting in 

order to maintain BP at 90 psi. NOTE: The railroad should be testing BP pressure it 

normally uses for train operations. 

5. It is also critical that the main reservoir is capable of obtaining a main reservoir (MR) 

pressure of 130 psi during the test. Ideally, the test reading should be taken at 130 psi 

MR on the MR pressure rise. It may be necessary to increase engine speed on 

locomotives that have mechanical driven air compressors, in order to achieve an MR 

pressure of 130 psi. 

6. The air flow indicator must read 60 cubic feet per minute (CFM) and be accurate within 

±3 CFM. On mechanical indicators that is equivalent to the width of the pointer. 

7. If the air flow indicator is not accurate within ±3 CFM, the indicator must be calibrated. 

The railroad may elect to perform this function on the locomotive or remove the indicator 

and send it out for calibration. 

(MP&E 04-01) When conducting inspections at locations that perform periodic locomotive 

maintenance, special attention should be given to performance of air flow indicator testing and 

calibration procedures, as well as the testing and calibration of locomotive air gauges and 

displays. Inspectors should verify that the tests are properly performed by randomly checking 

locomotives that are released from the shop after undergoing a periodic maintenance. On the 

random checks, request that the railroad properly perform a retest, and if the air flow indicator is 

not in compliance, appropriate enforcement action should be taken. If a location has a high 

incidence of non-compliance with air flow indicators and/or air gauges, immediately notify the 
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Regional MP&E Specialist to determine what additional enforcement action(s) should be taken. 
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Paragraph (e) states that when a Class I test is performed on an entire train the engineer shall be 

notified of the successful test. Most of the time this notification is provided to the engineer in 

writing, but it can be provided via a hand held radio, a cellular telephone, or communication with 

a train dispatcher, as long as it is provided to the crew prior to the train’s departure and a written 

or electronic record is created and maintained in the cab of the controlling locomotive until the 

train either reaches destination or another Class I test is performed on the entire train. If a 

relieving crew takes charge of a train and the information is not available for the oncoming crew, 

then a violation of the regulation has occurred. Inspectors should apply appropriate enforcement 

action based on whether this is a systemic or recurring problem on a case-by-case basis. In order 

for the railroad to advance the train beyond the point where the information is not available to 

the oncoming crew, the railroad would have to obtain the correct Class I test information via fax, 

telephone, etc. and provide that information to the crew, or conduct another Class I brake test 

and provide the crew with the new Class I information.The rule requires that the identity of the 

person(s) performing the Class I test be entered on the Class I test information. FRA will accept 

a full name, the first initial-last name, or an employee ID number to satisfy this requirement. 

FRA will not accept just initials or “carmen in north yard” or “foreign line” for this requirement. 

Inspectors should take appropriate enforcement action when this is discovered. Inspectors 

should also make sure that the crew does not have a computer print-out that indicates the 

conductor of that crew as the individual making the Class I test, unless that individual performed 

the test. 

The Class I brake test information is relevant only to the Class I test when it is performed on the 

entire train. The information does not have to be updated as cars are added to or removed from 

the train while the train is en route. Since the regulation requires the information to remain with 

the train until it reaches destination or another Class I test is performed on the entire train, the 

information shall not be altered. If a railroad changes the number of cars on the original slip, 

Inspectors should take appropriate enforcement action to correct the problem. 

§ 232.207 Class IA brake tests--1,000-mile inspection. 

For Class IA test locations, the most restrictive car or block of cars in the train will determine the 

location where this test must be performed. For example, if a train departs point A and travels 

500 miles to point B where it picks up a previously tested block of cars en route which has 

traveled 800 miles since its last Class I brake test and the crew does not perform a Class I brake 

test when entraining the cars, then the entire train must receive a Class IA brake test within 200 

miles from point B even though that location is only 700 miles from point A. 

Defective equipment may be moved from or past a location where a Class IA brake test is 

performed, only if all of the requirements contained in §232.15 have been satisfied. If the 

location is one meeting the criteria found in §232.15, the car should not be moved until the 

repairs are completed. 

As with the Class I brake test, in order to properly perform a Class IA brake test, both sides of 

the equipment must be observed sometime during the inspection process. Paragraph (c) contains 

the provision that requires railroads to designate and maintain a list of locations where Class IA 
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inspections will be performed. This list shall be made available to FRA upon request. If an 

Inspector needs this information, then the Regional office must be contacted so that the Regional 

office can make this request to the railroad in writing. 

A railroad cannot just designate a major city, if there are multiple locations in and around the city 

that can perform the Class IA test. Specific yard locations need to be identified or mile markers. 

FRA requires that it be notified at least 30 days in advance of any change to the list of Class IA 

test locations. FRA realizes that there may be occurrences or emergencies, such as derailments, 

that make it impossible or unsafe for a train to reach a location that the railroad has designated as 

a Class IA inspection site. Consequently, the rule permits railroads to bypass the 30-day written 

notification requirement in these instances provided FRA is notified within 24 hours after a 

designation has been changed. This paragraph also makes clear that failure to perform a Class 

IA brake test at a designated location will constitute a failure to properly perform the inspection. 

§ 232.209 Class II brake tests–intermediate inspection 

A Class II brake test is intended to ensure that the brakes on those cars added apply and release 

and that the added cars do not compromise the integrity of the train’s brake system. Therefore, a 

leakage or air flow test must be performed when the cars are added to the train to ensure the 

integrity of the train’s brake system. 

Both sides of the equipment must be observed sometime during the inspection process. The 

brakes shall apply on each car added to the train and remain applied until a release is initiated 

and a retest is allowed on those cars found with brakes not applied. It should be noted that, 

defective equipment may be moved from or past a location where a Class II brake test is 

performed only if all of the requirements in § 232.15 have been satisfied. 

Paragraph (b) also requires that the release of the brakes on those cars added to the train and on 

the rear car of the train be verified and allows railroads to conduct “roll-by” inspections for this 

purpose. 

Paragraph (c) permits an alternative to the rear car application and release portion of this test. 

This alternative permits the locomotive engineer to rely on a rear car gauge or end-of-train 

device to determine that the train’s brake pipe pressure is being reduced by at least 5 psi and then 

restored by at least 5 psi in lieu of direct observation of the rear car application and release. 

Paragraph (d) contains the requirements relating to the inspection of cars or blocks of cars added 

to a train while a train is en route. This paragraph makes clear that if cars are given a Class II 

brake test when added to a train, then the cars added must receive a Class I brake test at the next 

forward location where the facilities are available for performing such an inspection. 

Paragraph (f) contains the requirements relating to the adding of cars or blocks of cars while a 

train is en route. This paragraph informs railroads that cars picked up en route that have not been 

previously tested and kept connected to a source of compressed air are to receive a Class I brake 

test when added to the train. Alternatively, a railroad may elect to perform only a Class II brake 

test at the time that a car is added to the train en route, but FRA intends to make clear that when 
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this option is elected, the cars added in this fashion must be given a Class I brake test at the next 

forward location where facilities are available for providing such attention. 

§ 232.211 Class III brake tests–trainline continuity inspection 

The purpose of a Class III brake test is to ensure the integrity of the trainline when minor 

changes in the train consist occurs. Basically, a Class III brake test ensures that the train brake 

pipe is properly delivering air to the rear of the train. This inspection is designed to be 

performed whenever the continuity of the brake system is broken or interrupted. 

When a car or locomotive is added or removed from a train, the Class III test must be performed 

as prescribed in paragraph (b), which requires that the test cannot be performed until the BP 

pressure at the rear of the train is at least 60 psi, as indicated by an accurate gauge or end-of-train 

device, and a 20-psi brake pipe reduction made. 

When the continuity of the brake pipe is broken or interrupted with the train consist otherwise 

remaining unchanged, it must be determined that BP pressure is being restored to the rear of the 

train as indicated by a rear car gauge or end-of-train device prior to proceeding. In the absence of 

a rear car gauge or end-of-train device, a visual application and release of the rear car’s brakes 

can be made only if the train consist remains unchanged, which includes cars and locomotives. 

§ 232.213 Extended haul trains 

Railroads are permitted to designate trains as extended haul trains, which allows such trains to be 

operated up to 1,500 miles between brake inspections. 

The designation of such trains must be in writing to the Associate Administrator for Safety. The 

designation must include the originating location and destination of the extended haul portion for 

each train. As trains are added and/or deleted, the railroad must submit the revisions to the 

Associate Administrator for Safety. Headquarters will provide the updated lists electronically to 

the regions as they are submitted. Once a train is designated as an extended haul train, it must be 

operated as an extended haul train until the official list is revised and properly submitted to FRA. 

Changes cannot be made on a daily basis by a train dispatcher. All changes must be made in 

writing to the Associate Administrator for Safety as explained above. A railroad cannot make 

changes through a Regional office. 

Extended haul trains are permitted one pick-up and one set-out en route. If more than one pickup and/or one set-out occur, the Inspector should submit a violation for each occurrence. Also, a 

Qualified Mechanical Inspector (QMI) must perform the appropriate inspections of all pick-ups 

and set-outs. 

At no time will the FRA penalize a railroad for setting out a defective car during the extended 

haul train movement. These types of set-outs do not count against the one set-out rule. 

At a location where a car(s) is picked-up en route, as long as a QMI has performed the 
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appropriate inspections of the car, the train crew can add the car to their train and only have to 

perform a Class III brake test. The QMI does not have to be at the location to simply add the 

car(s) to the train. 

If a train is operating on two extended haul segments, another extended haul outbound inspection 

must be conducted by a QMI. Cars can be added and/or removed at this location, but it would 

have to count as one of the permitted pick-ups or set-outs en route. Whether this is done before 

the inbound/outbound inspection is performed is important as to compliance with the “one” pickup/one set-out rule. 

At the termination point of the extended haul portion of the extended haul run, unless this 

location is the final destination for the run, a Class I inspection of the train must be performed 

before the train can continue any further. 

§ 232.215 Transfer train brake tests 

A "Transfer train" is defined in § 232.5 of this rule as a train that travels between a point of 

origin and a point of destination, located not more than 20 miles apart. The definition makes 

clear a transfer train may pick up or deliver freight equipment while en route to its destination. 

Cars may be added to a transfer train while the train is en route, provided a transfer train brake 

test is performed at the location where the cars are added. The train is limited to a total of 20 

miles from its point of origin, not from the location where new cars are added. 

It is possible to operate a train for a distance of 60 miles on transfer train brake tests, provided a 

transfer brake test is performed on the entire train at each 20 mile interval. 

While the rule permits that transfer test to be conducted when the brake pipe is charged to 60 psi 

as indicated by a gauge at the rear of the train, with a 15 psi brake pipe reduction, it is 

permissible to conduct the test at 90 psi brake pipe pressure. However, if 90 psi is used, FRA 

expects a 20 psi brake pipe reduction be made since the 15 psi allowance was for the lower brake 

pipe pressure. 

Please note that the retest of a car for a brake application during the transfer test should be made 

using the same brake pipe pressure that is used during the original transfer test. If the transfer 

test is performed at 60 psi brake pipe pressure, then the retest can be made after the car is 

charged to 60 psi with a 15 psi reduction. If the transfer test is performed at 90 psi brake pipe 

pressure, then the retest shall be made at 90 psi with a 20 psi reduction. 

§ 232.217 Train brake tests conducted using yard air 

When Inspectors encounter a location where the yard air is less than 80 psi, they must ensure the 

leakage or air flow test is conducted at the proper brake pipe pressure after the locomotives are 

attached. 

While paragraph (d) contains the calibration requirements for yard test devices, it is FRA’s intent 
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that only the gauge be tested and calibrated every 92 days. Industry devices such as the “TimeO-Test” and/or individual railroad manufactured devices use a fixed 1/4-inch or 5/16-inch orifice 

to increase air pressure and a 1/4-inch orifice to reduce brake pipe pressure. FRA does not 

believe that these orifices need to be calibrated unless there is physical evidence of damage to the 

device. 

§ 232.219 Double heading and helper service 

Although the brake system on locomotives are required to be inspected on a daily basis, FRA 

continues to believe that a visual confirmation of the proper operation of a helper locomotive’s 

brakes must be made each time the locomotive is added to a train 

A helper locomotive found with inoperative or ineffective brakes is to be repaired prior to use or 

else removed from the train. If it cannot be repaired it must be tagged and taken to the nearest 

location for repairs. 

Paragraph (c) requires a Helper Link device or similar technology be designed with a distinctive 

alarm to notify the engineer of any loss of communication as well as reset capability in the cab of 

the locomotive available to the locomotive engineer. Such devices must be tested and 

recalibrated as necessary according the the manufacturer’s instructions every 365 days. 

Subpart D - Periodic Maintenance and Testing Requirements 

This subpart provides the periodic brake system maintenance and testing requirements for 

equipment used in freight and other non-passenger trains. 

Inspectors need to periodically monitor the activities of car repair facilities to ensure compliance. 

Check that the shop is capable of obtaining the single car test dates and that single car test are 

being performed on cars that have not received a single car test within the past 12 months. 

Check that handbrakes are being inspected and tested. If the brake shoes do not apply against the 

wheel when the handbrake is applied, the railroad should take corrective action or appropriate 

enforcement action should be taken by the Inspector. 

Monitor that single car tests are being properly performed on cars that require such tests and that 

the daily and periodic testing is being performed on the single car test devices. 

Paragraph (e) of § 232.303 contains the provisions permitting cars to be moved from a location 

where necessary repairs are made to a location where a single car or repair track air brake test 

can be performed, only if it cannot be performed at the same location where the repairs are 

conducted. FRA disagrees with the assertions of many railroads that air brake repairs should not 

be required at locations that lack the ability to perform single car or repair track air brake tests. 

Therefore, Inspectors should not entertain such rhetoric. 

Pursuant to 49 CFR § 232.305, a single car test is required to be performed on a car at least once 

every five years (eight years for new and rebuilt cars) or within the past 12 months if the car is 

on a repair track. Also, any car that is removed from a train with a defective air brake must 
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receive a single car test. Inspectors can request the railroad to provide the single car test dates 

for cars, preferably using the UMLER system. If a railroad cannot provide this information, the 

Inspector should notify the Regional Specialist, who in turn shall notify Headquarters. 

Additionally, Inspectors are encouraged to request a test date on each car that is being considered 

for civil penalty. If a car has not had a single car test within the five year period, another 

violation should be taken against the car. Inspectors should also periodically run a list of cars 

that have received attention in a shop or repair track to see if a car has received a single car test 

within the past 12 months. If not, a violation should be considered. 

Section 232.305(b)(1) requires that a single car test be performed on a car that has its brakes cutout or inoperative when removed from a train. This means that if the car is properly tagged with 

an inoperative brake and it is set-out of the train, it must have a single car test. If the railroad 

removes the car from the train with the brakes cut-out (with or without a defect tag) and the 

Inspector observes this, a single car test would have to be performed on that car. However, if the 

Inspector finds a car in a yard or siding with the brakes cut-out, the burden of proof is on the 

Inspector to establish whether the car was set out of a train with the brakes cut-out or some yard 

crew cut the brakes out as they were switching the car in a yard. The Inspector cannot assume the 

brakes were cut out when the car was set-out of the train. A defect tag or witness statement 

would suffice. 

Section 232.305(b)(5) identifies the various wheel defects that trigger a single car test on the car. 

This requirement applies when the railroad removes the wheel from the car for the defective 

wheel condition. This is especially true for the built-up tread condition, as there are no Federal 

regulations addressing built-up tread. The “why-made” code on the AAR billing record would 

have to be used for any enforcement action regarding non-compliance with performing a single 

car test for a built-up tread condition. 

Section 232.305(e) requires a single car test performed on every new or rebuilt car before it is 

placed in service. Inspectors should periodically monitor this activity at car manufacturing 

plants. 

When a car is on a shop or repair track, the piston travel must be checked. The limits for the 

piston travel range on cars equipped with 12-inch stroke (eight and one-half (81⁄2) or ten (10) inch 

diameter) brake cylinders has been changed. The new limit is six (6) to nine (9) inches. If piston 

travel is found to be less than six (6) inches or more than nine (9) inches when testing the brakes 

on the shop or repair track, the piston travel shall be adjusted to nominally 71⁄2 inches. This 

change is based on a waiver, docket number FRA-2004-19402, which was conditionally granted 

on August 30, 2005. Furthermore, the waiver also requires that these cars shall have the 

empty/load valve tested, if so equipped, as prescribed in AAR Standard S-486-04, Sections 4.6.1 

through 4.6.5, anytime a single car test is performed on the car, irrespective of whether the valve 

has been changed or not. Please note that this test is not required if the car is loaded, since the 

test can only be performed when the car is empty. 

Inspectors should ensure that railroads are conducting an inspection of the accuracy and 

operation of any brake indicators on cars so equipped. If the indicator is broken or unreadable, 

FRA expects corrections to take place while the car is on the shop or repair track. 
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Section 232.309(b) states that mechanical test devices such as pressure gauges, flow meters, 

orifices, etc., shall be calibrated once every 92 days. Paragraph (d) requires that the test 

equipment and single car test devices placed in service shall be tagged or labeled with the date its 

next calibration is due. A tag or label can be affixed to a single car test device and a brake 

cylinder test gauge, but it is difficult to tag or label a test coupling. If the test coupling is chained 

or cabled to the single car test device, then it would be considered as a “unit” if the single car test 

device and test coupling are both calibrated per S-486 by the same facility and the railroad can 

will also accept a test coupling that has an identifying mark or number (that is unique) inscribed 

on it that would be the same as a unique number or mark inscribed on the test device, that would 

make it a “unit” as discussed above. The tag or label on the test device would apply to the entire 

“unit.” 

(MP&E 98-63) Subpart E - End-of-Train Devices 

On May 31, 2001, Subpart E, End-of-Train Devices, became effective. In order to aid 

understanding of the inspection and testing requirements of the devices, as well as issues 

involving en route failures, a modified version of is provided below. 

When does the device have to be armed? 

The device has to be armed and operable from the time the train departs the point of installation, 

until the train reaches destination. According to 49 CFR § 232.407(f), if communication cannot 

be established at the location where the device is installed, the train may move up to one mile 

from that location at restricted speed, in order to establish communication. If communication is 

not established within the one-mile movement, the train must be stopped and the device must be 

either repaired or replaced and communication established before the train can continue, or train 

orders issued that restricts that train from exceeding 30 mph for the entire trip, provided the train 

does not traverse any defined heavy grade. If communication is established, the train must be 

stopped and the appropriate inspection and testing requirements of § 232.409 (a)-(c) must be 

satisfactorily performed before the train can continue. 

What tests have to be performed at the point of installation? 

It must be understood that installation includes both the front and rear device. When either of 

these devices are installed and before the train departs, the following must be performed: 

1. It must be determined that the identification code entered into the front unit is identical to 

the unique code of the rear unit. 49 CFR § 232.409(a). 

2. Determine that the quantitative value for brake pipe pressure displayed on the front unit is 

within 3 pounds per square inch of the reading displayed from either the rear EOT unit or 

a properly calibrated air gauge at the rear of the train. This reading must be compared 

after the train is charged. 49 CFR § 232.409(b). 

3. A test has to be made to ensure the device is capable of initiating an emergency power 
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brake application from the rear of the train. 49 CFR § 232.409(c). 

What is the test procedure to ensure the device is capable of initiating an emergency power 

brake application from the rear of the train? 

There are currently four acceptable methods of performing this test. The first three methods 

require attaching the rear-of-train device to the last car of the train, establishing brake pipe 

pressure, and arming the device. 

1. In the first method, the controlling locomotive would transmit an emergency brake 

application signal with the front unit manual switch causing an emergency application to 

be initiated from the rear of the train, thereby dumping the whole train into emergency. 

2. The second method requires closing the angle cock on the last or second-to-the-last car of 

the train, and then have the controlling locomotive transmit an emergency brake 

application signal with the front unit manual switch. Under this method only the last one 

or two cars of the train will effectuate an emergency brake application. 

3. Using the third method, an individual would close the angle cock between the rear-oftrain device and the last car. Then have the controlling locomotive transmit an 

emergency brake application with the front unit manual switch, so that an individual at 

the rear of the train can determine whether the emergency valve functions properly by 

either observing the emergency indicator pop out, or observing brake pipe pressure at the 

rear device go to zero while hearing the exhaust of air from the device. 

4. The final acceptable method of inspection is a bench test of the device (front and rear) 

which would be performed within a reasonable time period prior to the device being 

armed and placed on the train. 

Can anyone perform these tests? 

The EOT regulations do not establish a specific requirement concerning who may perform the 

necessary tests. However, according to § 232.409(c), if anyone other than a crew member 

performs these tests, the locomotive engineer has to be informed that the test (both front and rear 

device) was successfully performed. This can be by any means determined by the railroad to be 

appropriate. However, a written or electronic record of the notification has to be maintained in 

the cab of the controlling locomotive for the engineer at the point of installation. The notification 

must include the location, date and time the test was performed, and the name of the 

individual(s) who performed the test. If one individual tested the front device and another 

individual tested the rear device, the notification would have to include information for the two 

separate tests. This written information is not required at subsequent crew change points. 

Would these tests apply to a train using a distributive power unit (DPU) at the rear of the 

train? 

No. This type of train is excepted from the two-way EOT requirements, provided the train has a 
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locomotive located at the rear of the train, capable of making an emergency brake application 

through a command effected by radio telemetry, or by a crew member in radio contact with the 

lead (controlling) locomotive. 

What is a bench test? 

The purpose of this particular test is to ensure that the front unit will transmit an emergency 

brake application signal to the rear device and that the rear device is capable of initiating an 

emergency brake application from the rear of the train, as required by § 232.405(a). The bench 

test has to consist of testing both the front and rear units (devices) that will be used on the train. 

They can be tested independently of each other, as long as the test is performed at the location 

where the device will be installed on the train. 

Testing the rear unit requires applying air pressure to the device and then transmitting an 

emergency brake application from a front unit using the front unit manual switch. The individual 

performing the test would determine that the emergency valve functions properly by either 

observing the emergency indicator pop out or by observing the brake pipe pressure displayed on 

the gauge on the rear device go to zero and hearing the exhaust of air from the device. 

The front unit that will be used on the controlling locomotive of a train would be tested by 

transmitting an emergency brake application from the device using the front unit manual switch, 

and a rear device would have to successfully receive the signal and activate the emergency air 

valve. 

Both tests must be performed within a reasonable time period prior to the device being armed 

and placed on the train. 

What is a reasonable time period? 

A reasonable time period must be determined on a case-by-case basis, based on the factual 

situation at a specific location, as there are numerous factors that impact the notion of 

“reasonable.” The following discussion is intended as general guidance for Inspectors to consider 

in determining whether a bench test at a particular location was conducted within a reasonable 

time of its installation on a train. This discussion is not intended to create or establish any strict 

time requirements. The following factors should be considered: 

• The environment where the device is tested and stored: 

 Free from weather elements? 

 Free from excessive dust? 

 Free from dirt and grease? 

 Accessible to possible tampering? 

• Physical treatment of the device after a successful bench test. 

• Railroad’s tracking and monitoring of devices after testing. 

• Use of the locomotive after the testing of the front unit. 

• Past effectiveness of bench testing procedures at the particular location. 
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For example, if the devices are tested and stored in a controlled environment, that is free from 

weather elements, excessive dust, grease, and dirt, then a reasonable amount of time between the 

testing and installation of the device might be 8 hours or more. Whereas, in circumstances where 

the devices are haphazardly thrown into a corner of a shop or are placed in the rear of a truck to 

be bounced around a yard after being tested, then a reasonable amount of time may be one hour 

or less. Furthermore, the effectiveness of a railroad’s bench testing procedures should always be 

considered in determining what constitutes a reasonable time period. Consequently, Inspectors 

should provide detailed evidence and fully describe a railroad’s bench testing procedures in order 

to support any determination that the time period between the bench test and installation of a 

device on a train was not reasonable. 

Can devices be bench tested and taken to other locations for application? 

No, because § 232.409(c) requires the device shall be tested at the initial terminal or other point 

of installation. This implies that the device must receive the tests required by the EOT regulation 

at the location or yard where it will be installed on the train. 

What are the testing requirements if locomotive power is changed and a different front unit 

is used? 

At the point of installation, whether it is the front or rear device, all testing requirements apply. 

If the locomotive power is changed and a new front device is installed on the train, all testing 

requirements apply. If the front device is replaced with a device from a trailing locomotive, all 

testing requirements apply since this is a new installation of the front device. 

What about the calibration requirements? 

In accordance with § 232.409(d), both the front and rear units have to be calibrated for accuracy 

according to the manufacturer’s specifications and procedures at least once every 368 days. The 

test shall include testing radio frequencies and modulation. The 368 days does not include up to 

92 days of shelf-life prior to placing the unit in service. The date of the calibration, the location 

where the calibration is made, and the name of the person performing the calibration has to be 

legibly displayed on a weather-resistant sticker or other marking device affixed to the outside of 

the device (both the front unit and rear unit). It is the railroad’s responsibility to account for the 

shelf-life by either entering an in-service date on the sticker or the number of days of shelf-life 

on the sticker. If the device is integrated into the computer of the locomotive, the sticker 

information can be entered on Form FRA F6180-49A. The sticker information must be 

accessible to both FRA Inspectors and train crew members. Therefore, it cannot be locked in 

cabinets, out of view. 

Are railroads required to keep spare batteries at specific locations? 

No, it is within the railroad’s discretion to determine when and where batteries will be kept and 

charged. There are sufficient incentives for railroads to ensure that the batteries are sufficiently 
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charged at all times because of the speed restrictions imposed on trains that develop failures en 

route; and strict liability for failure of the batteries en route. If an Inspector can determine that a 

battery failed en route, submission of a violation should be strongly considered. 

What actions have to be taken when the device develops a failure en route? 

If the device develops a failure en route, the speed of the train is restricted to 30 mph. In 

addition to observing the 30 mph speed restriction, the train is not permitted to operate over a 

section of track with an average grade of two percent or greater over a distance of two 

continuous miles, unless the conditions contained at § 232.407(g) are met. 

On some units, front-to-rear failures and rear-to-front failures are displayed. Are both of 

these failures considered an en route failure? 

Since the intent of the rule is to have the capability of initiating an emergency brake application 

at the rear of the train, only the front-to-rear failure is considered an en route failure. The rear-tofront failure does not affect the ability of the device to initiate the emergency from the rear of the 

train. If the engineer is unable to determine if the communications failure is front-rear or rearfront, then any communications failure must be considered an en route failure and corrective 

action must be taken. 

Is an intermittent communication failure considered an en route failure? 

No, there has to be a continuous loss of communication between the front and rear unit for a 

period greater than 16 minutes and 30 seconds. However, based on existing designs of the 

devices currently used, anytime the display indicates a “comm loss,” the 16 minutes and 30 

seconds have elapsed and the locomotive engineer must comply with the restrictions required for 

the failure en route requirements. 

Can a train proceed over a heavy grade with a defective device? 

A train cannot proceed over a heavy grade unless the defective device is replaced with a fully 

operational device, or one of the following alternative methods is used: 

1. An occupied locomotive helper is attached to the rear of the train with the brake 

pipe connected and tested to ensure brake operation. The helper engineer will 

initiate and maintain two-way voice radio communication with the engineer on 

the head end of the train. If communication is lost prior to passing the crest of the 

grade, the train should be stopped until communication has been restored, if this 

can be done safely. If communication is lost once the descent has begun, the 

helper locomotive engineer and the head end engineer will act to stop the train if 

the train reaches a predetermined rate of speed that indicates a need for 

emergency braking. The predetermined rate of speed is established by the 

railroad and should be indicated in the railroad’s timetable. 

2. An occupied caboose is attached to the end of the train with a tested, functional 
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brake valve capable of initiating an emergency brake application from the 

caboose. The occupant of the caboose must establish and maintain radio voice 

communication with the head end engineer in the same manner as prescribed for 

the occupied locomotive helper. 

3. A radio-controlled locomotive is located at the rear of the train, and is under 

continuous control of the head end engineer by means of telemetry, and if the 

radio-controlled locomotive is capable of initiating an emergency brake 

application from the lead (controlling) locomotive. 

Does this mean the train would have to stop on a grade if a failure occurs? 

Whenever a failure occurs en route, the train is prohibited from operating over a section of track 

with an average grade of two percent or greater over a distance of two continuous miles. If the 

train develops the failure while traversing the grade, § 232.409(g)(2) allows the engineer to 

safely continue down the grade or to a specific siding, in accordance with the railroad’s operating 

procedures for bringing the train to a stop at the first available location, rather than bring the train 

to an immediate stop. 

If a helper locomotive is used on the head end of a train, does it have to be linked to the 

two-way EOT? 

If a locomotive helper is attached to the front of the train to help the train over a grade, it would 

not have to be linked to the two-way EOT provided that the locomotive that was originally 

controlling the train is still armed and capable of initiating an emergency brake command to the 

rear device and two-way voice radio is initiated and maintained by the helper locomotive 

engineer with the engineer of the original lead locomotive until the move is completed. If 

communication is lost, each engineer will immediately act to stop the train if the train reaches a 

predetermined rate of speed that indicates a need for emergency braking. The predetermined rate 

of speed is established by the railroad and should be indicated in the railroad’s timetable. This 

only applies to the extent necessary for the helper unit to provide power to get the train over the 

grade. 

If a train were to have problems and stalled in a tunnel where communication is lost, and it 

took longer than 16 minutes and 30 seconds to correct, could the train move out of the 

tunnel so that communications could be re-established, or is this a communications failure 

requiring other corrective measures? 

If this incident occurred, the train would be allowed to move out of the tunnel. Once out of the 

tunnel, if communication is not re-established, the train would have to be brought to an 

immediate stop. Corrective action for a communication failure would have to be taken. 

If a train has to be cut because it has insufficient power to get over a hill, what has to be 

done with regard to the two-way EOT? 

If a train has to be cut because there is insufficient power to pull it over a hill or grade, the device 
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may remain in place on the car at the rear of the train. It does not have to be advanced to the 

moving section of the train. This only applies to the extent necessary to traverse the grade and 

only while the train is divided for this procedure. 

Can a “Local Train” that is not equipped with a two-way EOT operate above 30 mph? 

A local train as defined in § 232.407(a)(3), that does not operate over a section of track with an 

average grade of 2 percent for 2 continuous miles, can run at authorized track speed without a 

two-way EOT. In many cases, this could be above 30 mph. 

Can a “work train” operate above 30 mph if it is not equipped with a two-way EOT? 

A work train as defined in § 232.407(a)(4), that does not operate over a section of track with an 

average grade of 2 percent for 2 continuous miles, can run at authorized track speed without a 

two-way EOT. This could be above 30 mph. 

Can any train be dispatched without a two-way EOT if it does not exceed 30 mph? 

Only if the train will not travel over a heavy grade as defined in § 232.407(a)(1), or is 

specifically excepted from the requirements found at § 232.407(e). 

If a train is equipped with an electronically controlled brake system (ECP), would an EOT 

be required? 

Yes, because the ECP train sets that are currently operating are an overlay system of regular 

pneumatic brakes. Since these trains can be run in either electronic or regular pneumatic mode, a 

two-way EOT device would have to be on the rear of the train. If the train is all electronic, the 

two-way EOT requirements will be covered by the waiver permitting this type of operation. 

(MP&E 98-62) Two-Way End-of-Train Device Flowchart 

The following flowchart (see Figure 6) was developed to provide a better understanding of when 

a two-way end-of-train device is required. All trains operating over the general railroad system 

have to comply with this regulation, unless a specific waiver is in effect for a particular 

operation. 
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Figure 6: Flow chart to determine two-way end-of-train device requirements 
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Subpart G—Electrinically Controlled Pneumatic (ECP) Brake Systems 

On October 16, 2008, FRA issued the final rule regarding Electronically Controlled Pneumatic 

(ECP) Brake Systems. See 73 Fed. Reg. 61512–61557. This added subpart G to part 232. The 

new subpart addresses ECP brake systems on freight trains. This regulation is designed to 

encourage the safe implementation and use of ECP brake system technologies. It contains 

specific requirements relating to design, interoperability, training, inspection, testing, handling 

defective equipment and periodic maintenance related to ECP brake systems. 

The ECP brake system radically improves the operation of the automatic air brake by using 

electrical transmissions to signal the application and release of brakes on each car in a train while 

still using the force of the brake shoe against the wheel. ECP brakes also greatly simplify the 

brake system by eliminating multiple pneumatic valves used by conventional brakes and 

replacing them with a printed circuit board and microprocessor, one electrically operated 

application valve, and one electrically operated release valve, with feedback of brake cylinder 

pressure for control. 

ECP brake technology requires adding equipment to locomotives and cars that is unique to the 

operation of ECP brakes. This system still requires a brake pipe to supply compressed air from 

the locomotive to each car’s reservoir in a train. The similarities between conventional and ECP 

brakes end there. Instead of using reductions and increases of the brake pipe pressure to convey 

application and release signals to each car in the train, ECP technology uses electronic signals, 

resulting in a virtually instantaneous application and release of brakes on each car in the entire 

train. Since the brake pipe pressure no longer serves as the communication medium in ECP 

brake equipped trains, the brake pipe is constantly supplied, or charged with compressed air from 

the locomotive regardless of whether the brakes are applied or released. In addition, ECP brake 

equipped trains offer graduated release, where a partial brake release command provides a partial 

and proportional brake release 

The adopted method of transmission of the application/release signal is via a two-wire cable 

based 

system. The electronic components are: 

 The Head End Unit (HEU) is the Engineer/ECP system interface that controls the brake 

application and release signals. On current ECP locomotives, this has been incorporated into 

the WABTEC and NYAB (see Figure 7) electronic locomotive systems and displays (see 

Figure 8). 
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Figure 7: New York Air Brake stand-alone head end unit 

Figure 8: Integrated ECP locomotive display 

 The Car Control Identification Device (CCID) (see Figure 9) and Car Control Device (CCD) 

(see Figure 10) are the microprocessor-based control units that receive the commands from 

the locomotive and sends status information and faults back to the locomotive. The CCD is 

an electronic control device that replaces the conventional pneumatic service and emergency 

portions during electronic braking functions. The CCD acknowledges and interprets the 

signals from the HEU and sends a warning signal to the locomotive in the event any 

component fails to appropriately respond to a braking command. Each CCID has a unique 

electronic address located in the Car ID Module, which is keyed to the car’s reporting mark 

and number including car type and configuration. The Webtec’s CCID and manifold are 

separate components (see Figures 9, 10 and 11). The NYAB’s CCID and manifold are a 

combined unit (see Figure 12). 
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Figure 9: Webtec’s Car Control & Identification Device (CCID) 

Figure 10: Webtec’s Car Control Identification Device CCID (with cover opened) 
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Figure 11: Webtec’s separate manifold 

Figure 12: New York Air Brake’s combined CCD and manifold 
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 The locomotive power supply (see Figure 13) which converts 74 VDC to 230 VDC, or 24 

VDC (Used for car sequencing), is used to power the HEU and CCDs. Under AAR 

standards, the single power supply will supply the necessary current and voltage to at least 

160 CCDs and an ECP–EOT. 

Figure 13: Locomotive power supply 

FRA defines ECP–EOT device in 49 CFR § 232.5 as the end-of-train device for ECP brake 

systems that is physically the last network node in the train, pneumatically and electrically 

connected at the end of the train to the train line cable operating with an ECP brake system. It 

shall transmit a status message (EOT Beacon) at least once per second and contain a means of 

communicating with the HEU, a brake pipe pressure transducer, and a battery that charges off 

the train line cable (see Figure 14). 
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Figure 14: ECP EOT 

Each car is connected to the locomotive via NYAB plug type connectors (see Figure 15) and 

junction boxes. The rear car is also equipped with an ECP-EOT device which is different than a 

normal pneumatic two-way EOT. 

Figure15: Inter-car connectors 

1. Located and guarded to provide sufficient vertical clearance. 

2. Not cause tripping hazard. 

3. Not hang with one end free whenever the equipment is being used in train movements. 

4. Not be positioned to interfere with the use of safety appliances. 

5. Not have any of the following conditions: 

- Badly chafed or broken insulations 
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- Broken plugs, receptacles, or terminals 

- Broken or protruding strands of wire 

Prior to October 16, 2008, FRA had conditionally granted a waiver in part, docket number FRA2006-26435, thereby allowing BNSF Railway and Norfolk Southern Railway to install ECP 

brake systems on pilot trains to demonstrate the safety and efficiency of the technology in 

revenue service. Under this wavier, trains equipped with ECP brakes were allowed to travel up 

to 3,500 miles without undergoing certain routine brake inspections, more than double the 

distance currently allowed by federal regulations. Now that the final rule has been issued this 

waiver is no longer in effect. 

§ 232.602 Applicability 

Subpart G applies to all railroads that operate a freight car or freight train governed by this part 

and equipped with an ECP brake system. Unless specifically excepted or modified in this 

section, all of the other requirements contained in this part are applicable to a freight car or 

freight train equipped with an ECP brake system. 

§ 232.605 Training Requirements 

Inspection, testing, and maintenance. Paragraph (a) provides that any railroad that operates a 

freight car or freight train that is equipped with an ECP brake system must adopt and comply 

with a training, qualification, and designation program for its employees that perform 

inspections, testing, or maintenance of ECP brake systems. The training program required by 

this section shall meet the requirements in § 232.203(a), (b), (e), and (f). This paragraph is also 

applicable to each contractor that performs inspections, testing, or maintenance on freight car or 

freight trains equipped with ECP brake systems. 

Operating rules. Paragraph (b) requires a railroad operating a freight train or freight car 

equipped with an ECP brake system to amend its operating rules to govern safe train handling 

procedures related to ECP brake systems and equipment under all operating conditions, which 

shall be tailored to the specific equipment and territory of the railroad. 

Locomotive engineers. Paragraph (c) establishes that a railroad operating a freight train or 

freight car equipped with an ECP brake system must incorporate safe train handling procedures 

related to ECP brake systems and equipment into its specific knowledge, skill, and ability criteria 

under 49 CFR part 240. 

§ 232.607 Inspection and testing requirements 

Initial terminal. Paragraph (a) establishes that a freight train operating in ECP brake mode shall 

receive a Class I brake test as described in § 232.205(c) by a qualified mechanical inspector 

(QMI) and shall receive a pre-departure freight inspection pursuant to part 215 of this chapter by 

an inspector designated under § 215.11 of this chapter at its point of origin (initial terminal). 
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Trains en route. Paragraph (b) provides that except for a unit or cycle train, a train operating in 

ECP brake mode shall not operate a distance that exceeds its destination or 3,500 miles, 

whichever is less, unless another inspection meeting the requirements of paragraph (a) of this 

section is performed on the train. A unit or cycle train operating in ECP brake mode shall 

receive the inspections required in paragraph (a) of this section at least every 3,500 miles. 

A freight train operating in ECP brake mode shall receive a Class I brake test as described in 

§ 232.205(c) by a qualified person at a location where the train is off air for a period of more 

than 24 hours or 80 hours, if the train remains inaccessible to the railroad and in an extended-offair-facility. 

Cars added en route. Each car equipped with an ECP brake system that is added to a train 

operating in ECP brake mode shall receive a Class I brake test as described in § 232.205(c) by a 

qualified person, unless all of the following are met: 

• The car has received a Class I brake test by a QMI within the last 3,500 miles; 

• Information identified in § 232.205(e) relating to the performance of the previously 

received Class I brake test is provided to the train crew; 

• The car has not been off air for more than 24 hours; and 

• A visual inspection of the car’s brake systems is conducted to ensure that the brake 

equipment is intact and properly secured. This may be accomplished as part of the 

inspection required under § 215.13 of this chapter and may be conducted while the car is 

off air. 

Each car and each solid block of cars not equipped with an ECP brake system that is added to a 

train operating in ECP brake mode shall receive a visual inspection to ensure it is properly placed 

in the train and safe to operate and shall be moved and tagged in accordance with the provisions 

contained in § 232.15. 

Class III brake tests. A freight train operating in ECP brake mode shall receive a Class III brake 

test as described in § 232.211(b), (c), and (d) at the location where the configuration of the train 

is changed, including: 

• Where a locomotive or caboose is changed. 

• Where a car or solid block of cars is added to the train. 

• Where a car or solid block of cars is removed from the train. 

• Whenever the continuity of the brake pipe or electrical connections is broken or 

interrupted with the train consist otherwise remaining unchanged. 

Initialization. Paragraph (e) states that the freight train shall be initialized when the following 

occurs: 

• Class I brake test. 
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• Class III brake test. 

• When the ECP brake system is powered on. 

The initialization process shall, at minimum, be in accordance with AAR Series Standards S4200 and be performed in the sequential order of the vehicles (freight cars) in the train. Once the 

ECP brake system is initialized, the train crew must ensure that the total number of cars indicated 

by the by the ECP brake system is the same as the total number of cars indicated in the train 

consist. 

Modification to existing brake tests. In lieu of the specific brake pipe service reductions and 

increases required in subpart C of this part, an electronic signal that provides an equivalent 

application and release of the brakes shall be used when conducting any required inspection or 

test on a freight car or freight train equipped with an ECP brake system and operating in ECP 

brake mode. 

In lieu of the specific minimum piston travel ranges contained in § 232.205(c)(5), the piston 

travel on freight cars equipped with ECP brake systems shall be within the piston travel limits 

stenciled or marked on the car or badge plate consistent with the manufacturers’ recommended 

limits, if so stenciled or marked. 

Exceptions. A freight car or a freight train shall be exempt from the requirements contained in 

§§ 232.205(a) and (b), 232.207, 232.209, and 232.211(a) when it is equipped with an ECP brake 

system and operating in ECP brake mode. 

§ 232.609 Handling of defective equipment with ECP brake systems. 

Paragraph (a) requires ninety-five percent (95%) of the cars in a train operating in ECP brake 

mode shall have effective and operative brakes prior to use or departure from the train’s initial 

terminal or any location where a Class I brake test is required to be performed on the entire train 

by a qualified mechanical inspector pursuant to § 232.607. 

Paragraph (b) provides that a freight car equipped with an ECP brake system that is known to 

have arrived with ineffective or inoperative brakes at the location of a train’s initial terminal or at 

a location where a Class I brake test is required under § 232.607(b) shall not depart that location 

with ineffective or inoperative brakes in a train operating in ECP brake mode unless: 

• The location does not have the ability to conduct the necessary repairs; 

• The car is hauled only for the purpose of repair to the nearest forward location where the 

necessary repairs can be performed consistent with the guidance contained in § 232.15(f); 

• The car is not being placed for loading or unloading while being moved for repair unless 

unloading is necessary for the safe repair of the car; 

• The car is properly tagged in accordance with §232.15(b). 

Pursuant to paragraph (c), a freight car equipped with only conventional pneumatic brakes shall 

not move in a freight train operating in ECP brake mode unless it would otherwise have effective 

and operative brakes if it were part of a conventional pneumatic brake equipped train or could be 
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moved from the location in defective condition under the provisions contained in § 232.15 and is 

tagged in accordance with § 232.15(b). 

A freight train operating in ECP brake mode shall not move if less than 85% of the cars in the 

train have operative and effective brakes. However, after experiencing a penalty stop for having 

less than 85% operative and effective brakes, a freight train operating in ECP brake mode may 

be moved if all of the following are met: 

• The train is visually inspected; 

• Appropriate measures are taken to ensure that the train is safely operated to the location 

where necessary repairs or changes to the consist can be made; 

• A qualified person determines that it is safe to move the train; 

• The train is moved in ECP brake Switch Mode to the nearest forward location where 

necessary repairs or changes to the consist can be made. 

Under paragraph (e), a freight car or locomotive equipped with an ECP brake system that is 

found with inoperative or ineffective brakes for the first time during the performance of a Class I 

brake test or while en route may be used or hauled without civil penalty liability under this part 

to its destination, not to exceed 3,500 miles; provided, all applicable provisions of § 232.609 are 

met and the defective car or locomotive is hauled in a train operating in ECP brake mode. 

A freight car equipped with an ECP brake system that is part of a train operating in ECP brake 

mode that is found with a defective non-brake safety appliance may be used or hauled without 

civil penalty under this Part to the nearest forward location where the necessary repairs can be 

performed consistent with the guidance contained in §232.15(f). 

A train operating with conventional pneumatic brakes shall not operate with freight cars 

equipped with stand-alone ECP brake systems unless: 

• The train has at least the minimum percentage of operative brakes required by § 

232.609(h) when at an initial terminal or § 232.609(d) when en route; and 

• The stand-alone ECP brake equipped cars are: 

o Moved for the purpose of delivery to a railroad receiving the equipment or to a 

location for placement in a train operating in ECP brake mode or being moved for 

repair to the nearest available location where the necessary repairs can be made in 

accordance with §§232.15(a)(7) and (f); 

o Tagged in accordance with § 232.15(b); 

o Placed in the train in accordance with §232.15(e). 

Paragrph (h) allows a train equipped and operated with conventional pneumatic brakes to depart 

an initial terminal with freight cars that are equipped with stand-alone ECP brake systems 

provided all of the following are met: 
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1. The train has 100% effective and operative brakes on all cars equipped with conventional 

pneumatic brake systems; 

2. The train has at least 95% effective and operative brakes when including the freight cars 

equipped with stand-alone ECP brake systems; 

3. The requirements contained in § 232.609(g) are met. 

Tagging of defective equipment. A freight car equipped with an ECP brake system that is found 

with ineffective or inoperative brakes will be considered electronically tagged under § 

232.15(b)(1) and (b)(5) if the car is used or hauled in a train operating in ECP brake mode and 

the ECP brake system meets the following: 

1. The ECP brake system is able to display information in the cab of the lead locomotive 

regarding the location and identification of the car with defective brakes; 

2. The information is stored or downloaded, is secure, and is accessible to FRA and 

appropriate operating and inspection personnel; and 

3. An electronic or written record of the stored or downloaded information is retained and 

maintained in accordance with § 232.15(b)(3). 

§ 232.611 Periodic maintenance 

Paragraph (a) requires, in addition to the maintenance requirements contained in § 232.303(b) 

through (d), a freight car equipped with an ECP brake system shall be inspected before being 

released from a shop or repair track to ensure the proper and safe condition of the following: 

1. ECP brake system wiring and brackets; 

2. ECP brake system electrical connections; and 

3. Car-mounted ECP brake system components. 

Exception. A freight car equipped with a standalone ECP brake system is excepted from the 

single car test requirements contained in § 232.305(b)(2) and (f). 

§ 232.613 End-of-train (EOT) devices 

An ECP–EOT shall, at a minimum, serve as the final node on the ECP brake circuit, provide a 

cable terminal circuit, and monitor, confirm, and report train, brake pipe, and train line cable 

continuity, cable voltage, brake pipe pressure, and the status of the ECP–EOT device battery 

charge. 

A railroad shall not move or use a freight train equipped with an ECP brake system unless that 

train is equipped with a functioning ECP–EOT device approved pursuant to paragraph (a) of this 

section and the railroad complies with paragraph (b) of this section. The ECP–EOT device must 

be properly connected to the network and to the train line cable at the end of the train. 
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Exception. A freight train operating in ECP brake mode is excepted from the end-of-train device 

requirements contained in subpart E of this part, provided that it is equipped with an ECP–EOT 

device complying with this section. 

Note: MP&E TB 09-02 New Source/Defect Codes for Electronically Controlled Pneumatic 

Brake Equipment Inspections and New Inspection Report Requirements on Out-Shopped 

Locomotives and Cars. Inspectors should review the technical bulletin related to ECP Inspection 

Activity and Out-Shopped Inspection Activity. 

Guidance for Appendix B to Part 232 — Part 232 Prior to May 31, 2001 as Clarified 

Effective April 10, 2002 

(MP&E 98-59) Train Brake Inspections 

When performing an initial terminal train air brake test under 49 CFR §232.12(c)-(j), an 

inspection of the train brakes shall be made to determine that the brakes are applied on each car, 

the piston travel is correct, brake rigging does not bind or foul, and that all brake equipment is 

properly secured. The 1,000-mile train air brake test under 49 CFR §232.12(b) also requires that 

the brakes apply on each car in response to a 20-pound service brake pipe pressure reduction and 

that the brake rigging is properly secured and does not bind or foul. For TMX Truck Mounted 

Brakes, see Wabtec Indicator at end of this section. 

Although the regulation does not specify the physical actions necessary to conduct a proper 

inspection, a railroad may fulfill the inspection requirement only when its inspectors position 

themselves in a way that permits the required observations noted above to be made. Obviously, a 

railroad inspector can visually inspect only what he or she is in a position to see. As the vast 

majority of all freight cars are equipped with air brake equipment (brake cylinders, brake 

indicators, brake rigging, etc.) that cannot be observed when inspections are made from only one 

side of the car, a proper initial terminal or 1,000-mile train airbrake inspection shall be 

performed by inspecting both sides of every car in the train. 

The following inspection practice would satisfy the regulations. After cars are assembled, a 

qualified individual, while connecting the air hoses on one side, performs an inspection of the 

brake equipment to ensure that brake components are properly secured, the brake rigging is not 

binding or fouling, and that brake shoes are in proper condition. The brake system is then 

charged and the air pressure at the rear of the train is checked to ensure it is at the required level. 

At that point, the brakes are applied and the qualified individual then performs a brake inspection 

on the other (second) side of the train to ensure that the brake components and rigging are 

properly secured and do not bind or foul, and that the brake shoes are against the wheel. During 

this inspection the individual will also check for proper piston travel, crossing over the cars to 

side one if the piston travel cannot be observed from side two. At the conclusion of this 

inspection, the brakes are then released and the individual then walks the release of the brakes or 

observes the brake release as the train rolls by at a low speed. If a roll-by inspection of the brake 

release is performed, the individual performing the inspection must have some method of 
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communicating with the train crew the results of the inspection. FRA believes that an inspection 

of the brake components, rigging, and shoes must be conducted on both sides of virtually every 

car sometime during the inspection process. 

A moving utility vehicle may be used in the performance of these inspections. However, these 

inspections must be made at a speed and in a manner that will permit the qualified person to 

clearly observe and determine the condition of the air brake equipment and that the piston travel 

is within limits. 

Train air brake tests that are not conducted in compliance with this interpretation shall be 

considered to be in non-compliance with the regulations. However, as with any regulatory 

requirement, inspectors should exercise discretion in how §232.12 is enforced so that our limited 

resources can be focused on matters likely to produce the greatest safety benefit. The general 

criteria for determining when enforcement action is appropriate, and which action to take, are set 

forth in 49 CFR Part 209, Appendix A. A railroad’s history of compliance with the relevant set 

of regulations, especially at the specific location involved, must be considered along with the 

kind and degree of potential safety hazard a condition poses in light of the immediate factual 

situation. Where compliance with train air brake testing requirements is poor, and improper 

inspections or no inspections are being performed, the failure to inspect or improper inspection 

can — along with the physical defects found on the cars—be strong enforcement candidates. 

Conversely, if a railroad is generally doing a good job in terms of compliance with the train air 

brake testing requirements at a particular location, the one-time failure to conduct a proper 

inspection at that point more likely is not a condition that poses a significant safety hazard. 

Violation reports alleging an improper train air brake test due to the failure to inspect both sides 

of the train as outlined above must specify precisely how the inspection was improper and 

include supporting evidence for review (e.g. detailed evidence that the brake equipment on one 

or more cars in the train—citing the specific component or components—could not be properly 

observed from only one side of the train). 

(MP&E 98-45) Initial Terminal Air Brake Tests at Remote Locations 

This technical bulletin provides guidance to Inspectors regarding the performance of initial 

terminal air brake tests at remote locations. There appears to be some confusion as to what is 

required when a railroad performs initial terminal brake tests at these remote locations. It has 

been brought to FRA’s attention that some trains at these remote locations, after receiving an 

initial terminal brake test pursuant to 49 CFR 232.12, are departing locations with cars having 

inoperative or cut-out air brakes. 

The regulation requires 100% operative brakes on trains departing initial terminals. FRA does 

not believe safety would be advanced by allowing something less than this at these remote 

locations. Therefore, when initial terminal brake tests are performed at these remote locations 

FRA expects the requirements contained in 232.12 to be followed. Consequently, if a car is 

found to have defective or inoperative brakes when the initial test is performed, the car must 

either be repaired or set-out of the train before the train departs. 

(MP&E 99-01) Clarification for Initial Terminal Road Train Air Brake Tests - Section 

232.12(d)(1) 
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Periodically, FRA receives inquiries concerning the amount of brake pipe reduction required 

when performing an initial terminal brake test. In 1982, FRA issued a technical bulletin (TB) 

stating FRA’s policy. The following information from the earlier TB is still in effect and should 

clear up any misunderstandings regarding this matter. Inspectors should be governed 

accordingly. 

In recognition of the objectives of the train air brake tests, the pressure-maintaining 

characteristics of the 26L locomotive air brake equipment, the greater sensitivity of modern 

control valves on freight cars, and good practice with respect to cutting the brake pipe pressuremaintaining feature out and in, an alternative brake pipe reduction sequence will provide an 

equally acceptable Initial Terminal Air Brake Test when 26L type equipment is utilized. 

A single brake pipe reduction of a minimum of 20 pounds, but not to exceed a full service 

reduction, will produce similar results and may be made in place of the specified sequence 

required in Section 232.12(d)(1) of a 15-pound reduction followed by an increase to full service. 

(MP&E 00-01) Enforcement Guidance for Inspecting and Testing Brakes on Cars while on 

Shop or Repair Track 

The following guidance was developed to alleviate confusion over the testing and repairing 

requirements of brakes on cars that are repaired on a shop or repair track. Particularly, when a 

mobile repair vehicle is involved. 

49 CFR 232.17(a) contains certain inspection and testing requirements of a car’s brake system, 

when a car is on a “shop” or “repair” track. For example; an application and release of brakes 

must be performed, piston travel must be inspected and adjusted (if necessary), and certain brake 

system components must be inspected to ensure they are properly positioned and secured. In 

addition, such cars must receive periodic attention in accordance with the requirements of the 

currently effective AAR Code of Rules for cars in interchange. AAR rules require that any car 

on a shop or repair track receive a repair track air brake test if such attention has not been 

provided to the car within the previous twelve months. 

The current regulation does not define what constitutes a shop or repair track. Although AAR’s 

Field Manual of Interchange Rules contains a definition of shop/repair track, FRA believes that 

AAR’s definition is too narrow and does not adequately delineate what constitutes a repair track 

for the purposes of §232.17(a). FRA believes the definition fails to adequately consider 

locations where mobile repair vehicles serve in the same capacity as a fixed repair facility and 

locations where railroads designate tracks as “expedite” or “light repair” tracks for the purpose of 

performing minor repairs. 

In 1994, FRA provided guidance in Technical Bulletin MP&E 94-18, that only light or minor 

repairs are to be conducted on tracks designated as “expedite” or “light repair” tracks. Currently, 

FRA does not require railroads to perform air brake related inspections and tests, pursuant to 

§232.17(a), on cars receiving minor repairs (i.e. straighten safety appliances, replace handholds, 

replace air hoses, adjust lading, replace coupler knuckle pin, knuckles, etc.), provided the repair 

work is performed on tracks located outside of a repair shop area. Nor does FRA require the 

performance of these inspections and tests on a car if a mobile repair vehicle is sent to a remote 
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location to make necessary repairs to the equipment. 

However, at locations where a railroad has designated specific tracks to perform repairs on a 

regular and consistent basis, and when the repairs conducted on those tracks include major repair 

work (i.e., wheel change, coupler replacement, draft gear repair, repairs requiring an air jack, 

etc.), FRA considers those tracks to be repair tracks for the purposes of §232.17(a). This includes 

locations where mobile repair vehicles have replaced a fixed repair facility or serve in the same 

capacity as a fixed repair facility. FRA believes it is both illogical and inconsistent with the 

intent and meaning of the existing regulations to exempt tracks at locations where repairs of all 

types are regularly and consistently performed, from being considered repair tracks merely 

because they are serviced by a mobile repair vehicle. Furthermore, it would be inconsistent with 

previous guidance provided by FRA to allow major repair work to be performed on the 

“expedite” or “light repair” tracks, merely because the repairs are performed by a mobile repair 

vehicle. It should be stressed that FRA does not intend to prevent a railroad from designating 

certain tracks for conducting minor repairs and certain tracks for conducting major repairs at the 

same location. 

Consequently, FRA considers the provisions of §232.17(a) applicable to fixed repair facilities 

and any location where repairs of all types are regularly and consistently performed, regardless 

of whether a mobile repair vehicle is used to conduct the repairs. FRA does not consider tracks 

that are designated only for minor repairs to be a repair track pursuant to §232.17(a); provided 

such track is used only to conduct minor repairs. However, if a major repair is performed on a 

car located on a track designated for minor repairs, then the car is subject to the provisions of 

§232.17(a) before it can be placed in service. 

(MP&E 98-40) 1000 Mile Interpretation - 49 CFR 232.12(b) 

Trains must receive an intermediate inspection at points not more than 1,000 miles apart. It is the 

carrier’s responsibility to designate the points where the 1,000 mile inspection will be made and 

provide this information to FRA personnel upon request. 

All mileage accumulated from the point of the initial terminal air brake test will count toward the 

1,000-mile requirements in Section 232.12(b). It should be noted that mileage accrued in 

Canada and Mexico will count toward the 1,000-mile requirements. When cars are received in 

interchange, the receiving railroad is responsible for knowing the distance that all of the cars 

have travelled since their last inspection. 

(MP&E 98-46) Handling of Defective Cars at Intermediate Inspection Locations 

The following provides guidance to Inspectors when considering enforcement action for the 

improper handling of cars found with inoperative or cut-out air brakes at locations where 

intermediate air brake inspections are performed. FRA is concerned that some railroads are 

moving cars found with inoperative or cut-out air brakes during intermediate brake inspections 

from that inspection location, when repairs of those cars could possibly have been made at that 

location. Therefore, FRA feels that some general guidelines should be provided to Inspectors in 

the field to aid them in determining whether the location is a place where the repairs could be 

effectuated. 
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The statutory provisions contained in 49 USC § 20303 (previously 45 USC Section 13) governs 

the movement of equipment with defective power brakes. This only allows the railroad to move 

the defective equipment from the place where the defect is first discovered to the nearest location 

where the necessary repairs can be made. This movement can either be on the railroad where 

first discovered or at the option of the connecting railroad, on the line of the connecting railroad 

if the move is no farther than the location on the line where the defect was first discovered. Thus 

in order to properly move a car for repairs, the railroad must know the defect exists. Although 

the new regulations provide for tagging requirements in 2004, there are currently no tagging 

requirements for power brake defects. At interchange, a railroad can refuse to accept a defective 

car. Until the receiving railroad accepts the car by moving it or otherwise exercising control 

over it, it is not liable for civil penalties nor is it required to make any repairs. It should be noted, 

however, that the delivering railroad remains liable for each defective car it tenders in 

interchange. 

The statutory provision contained in 49 U.S.C. § 20303 is an affirmative defense to be 

established by the railroad. There are seven elements which must be established: 

• The car was properly equipped with power brakes in the beginning. 

• The car became defective while being used by railroad on its line. 

• The railroad discovered the defect prior to movement. 

• The movement was from the place where the defect was first discovered. 

• Repairs could not be made at the location where the defect was first discovered. 

• Movement was necessary to make the necessary repairs. 

• The car moved only to the nearest available point where the necessary repairs could be 

made. 

The final rule on freight power brakes contains guidelines to be considered by FRA Inspectors 

and railroads in determining what constitutes the nearest location where necessary repairs can be 

performed. See 49 CFR § 232.15(f). The guidelines are equally applicable to determining such 

locations for all safety appliance defects. The guidelines must be applied on a case-by-case basis 

to determine if the railroad acted in good faith in moving defect equipment. The following 

locations should be considered when applying the guidelines discussed in detail below: 

C Locations where a mobile repair truck is used on regular basis; C Locations where a mobile 

repair truck originates or is permanently stationed; C Locations with an operative repair track or 

repair shop; and C Locations where railroad performs mechanical repairs other than power brake 

repairs. 

In determining whether a location, noted above, is capable of making a particular repair the 

following factors must be considered: 

 The accessibility of the location to persons responsible for making repairs; 

 The presence of hazardous conditions that affect the ability to safely make repairs of the 

type needed at the location; 

 The nature of the repair necessary to bring the car into compliance; 

 The need for railroads to have in place an effective means to ensure the safe and timely 
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repair of equipment; 

 The relevant weather conditions at the location that affect accessibility or create 

hazardous conditions; 

 A location need not have the ability to effectuate every type of safety appliance repair in 

order to be considered a location where some power brake repairs can be made; 

 A location need not be staffed continuously in order to be considered a location where 

power brake repairs can be performed; 

 The ability of a railroad to perform a single car test at a location shall not be considered; 

and 

 The congestion of work at a location shall not be considered. 

In addition to considering the factors noted above, the following factors must be considered in 

determining whether the location is the nearest location where the necessary repairs can be made: 

Distance to the location — Although this is a key factor it should not be the determining factor. 

This must be considered in conjunction with all the factors previously noted as well as the 

following safety considerations: 

 The safety of the employees responsible for getting the equipment to or from a particular 

location, and 

 The safety hazards involved in moving the equipment in the direction of travel necessary 

to get it to a particular location. If the location where an intermediate inspection is 

performed is not a location where the necessary repairs can be made, then the car may be 

moved for repair. This movement for repair must be made in accordance with 49 U.S.C. 

§ 20303. 

§20303. Moving defective and insecure vehicles needing repairs 

(a) General — A vehicle that is equipped in compliance with this chapter whose equipment 

becomes defective or insecure nevertheless may be moved when necessary to make repairs, 

without a penalty being imposed under section 21302 of this title, from the place at which the 

defect or insecurity was first discovered to the nearest available place at which the repairs can 

be made—

 (1) on the railroad line on which the defect or insecurity was discovered; or

(2) at the option of a connecting railroad carrier, on the railroad line of the connecting 

carrier, if not farther than the place of repair described in clause (1) of this section. 

(b) USE OF CHAINS INSTEAD OF DRAWBARS — A vehicle in a revenue train or in 

association with commercially-used vehicles may be moved under this section with chains 

instead of drawbars only when the vehicle contains livestock or perishable freight.

(c) Liability —The movement of a vehicle under this section is at the risk only of the railroad 

carrier doing the moving. This section does not relieve a carrier from liability in a proceeding to 

recover damages for death or injury of a railroad employee arising from movement of a vehicle 
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with equipment that is defective, insecure, or not maintained in compliance with this chapter. 

(MP&E 98-6) Bottom Rod Safety Support 

“Bottom rod safety supports” are only required on those cars that have the bottom rod or 

handbrake bottom rod below the bolster. There are normally three types of bottom rod safety 

supports in use. The most common is the heavy wire type (Creco) that fits over the brake beam, 

with underslung loops to cradle the bottom rod should it become disengaged from the rest of the 

rigging. The handbrake bottom rod used with the brake beam mounted cylinder, generally has a 

loop or strip attached to each side of the truck bolster. This allows the handbrake to operate 

freely and acts as a safety guard. There is an older type that can be attached to the spring plank 

and a newer cable type. 

(MP&E 98-8) Air Brake System - Reservoir Connecting Pipes 

There have been incidences where Inspectors have detected freight cars in-service that have 

reservoir connecting pipes incorrectly applied. The auxiliary portion of the reservoir was 

connected to the emergency portion of the brake valve and the emergency portion of the 

reservoir was connected to the service portion of the brake valve. Inspectors should be alert to 

this condition and take appropriate action when detected. 

(MP&E 98-11) Testing of Handbrakes on Locomotives Equipped with an Air Release 

Valve 

On some locomotives, the application of the handbrake actuates an air release valve to the brake 

cylinder on the side of the truck where the handbrake functions. This system is necessary 

because the brake cylinder body has to be moved by the application of the handbrake and if the 

piston is extended, the cylinder body cannot be moved. When the release valve is functioning 

properly, it will relieve the pressure and allow the piston to retract so that the application of the 

handbrake will force the cylinder body toward the wheel. If the release valve does not function 

as intended and the handbrake is applied with the piston extended, the locomotive will not have 

any holding brakes when the air leaks off. FRA has been advised that there have been incidents 

of roll-away locomotives because of the failure of this release valve. In many cases, employees 

have applied the handbrake and shut down locomotives, only to discover later that the handbrake 

was not applied after the air leaked off. 

All Inspectors are reminded that they are not to involve themselves in the manipulation of any 

apparatus that may cause or allow an adverse condition in any way. Testing for the above 

described condition must be done only by carrier personnel. 

(MP&E 98-15) Conditional Use of Air Flow Method For Train Air Brake Qualifications as 

an Alternative To the Leakage Test For Trains 

The following conditions were given to the Association of American Railroads for use of the air 

flow method (AFM) for train air brake qualifications: 
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1. Each controlling locomotive on a train qualified by the AFM shall be provided with an 

operational air flow indicator; 

2. Participating railroads shall provide an operational end-of-train device (see 49 CFR 

Section 232.19 - 232.25) on all trains except transfer and yard trains with movements not 

exceeding 20 miles; 

3. The AFM will apply only to trains using locomotives that are equipped with an air flow 

indicator that conforms with FRA’s conditions, AAR specifications and calibration 

procedures, and 26-L freight locomotive air brake equipment; 

4. When the AFM is used for train air brake qualifications, the air brake system shall be 

charged within 15 psi of the highest locomotive feed valve pressure used by that railroad 

and air flow shall not exceed 60 cubic feet per minute (CFM); 

5. The air flow indicator must be calibrated for accuracy at periodic intervals not to exceed 

92 days; 

6. The air flow indicator shall be clearly visible and legible in daylight and darkness from 

the engineer’s normal operating position; 

7. The air flow indicator gauge shall be clearly and uniformly marked to indicate direct 

reading of air flow in 10 CFM increments from at least 10 CFM to 80 CFM, with 

numerals indicating, at a minimum of 20, 40, 60, and 80 CFM for continuous monitoring 

of the air flow into the brake pipe. 

8. The air flow indicator calibration test orifices shall be calibrated at temperatures of not 

less than 20 degrees Fahrenheit; 

9. When a train qualified by the AFM is in operation and experiences an increase in brake 

pipe air flow and/or an increase in brake pipe gradient and the movable pointer does not 

return to the limits established in the initial terminal train air brake test within a 

reasonable time, the train crew shall stop the train for inspection and repair leaks, if 

detected. If unable to make repairs the crew should arrange to set out defective cars 

and/or proceed with due caution to the next location where corrective action can be taken; 

10. All participating railroads shall provide FRA a list of locations where calibrations will be 

performed and of locations which will be provided with test orifices. Changed, deleted, or 

additional locations will be reported to FRA within 92 days; and 

11. All personnel involved with the AFM of testing of train’s air brake systems and operating 

such trains must be given training and be aware of and understand the conditions of the 

waiver. 

12. Participating railroads shall provide an operational end-of-train device (see 49 CFR 

Section 232.19 - 232.25) on all trains except transfer and yard trains with movements not 
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exceeding 20 miles; 

13. The AFM will apply only to trains using locomotives that are equipped with an air flow 

indicator that conforms with FRA’s conditions, AAR specifications and calibration 

procedures, and 26-L freight locomotive air brake equipment; 

14. When the AFM is used for train air brake qualifications, the air brake system shall be 

charged within 15 psi of the highest locomotive feed valve pressure used by that railroad 

and air flow shall not exceed 60 cubic feet per minute (CFM); 

15. The air flow indicator must be calibrated for accuracy at periodic intervals not to exceed 

92 days; 

16. The air flow indicator shall be clearly visible and legible in daylight and darkness from 

the engineer’s normal operating position; 

17. The air flow indicator gauge shall be clearly and uniformly marked to indicate direct 

reading of air flow in 10 CFM increments from at least 10 CFM to 80 CFM, with 

numerals indicating, at a minimum of 20, 40, 60, and 80 CFM for continuous monitoring 

of the air flow into the brake pipe. 

18. The air flow indicator calibration test orifices shall be calibrated at temperatures of not 

less than 20 degrees Fahrenheit; 

19. When a train qualified by the AFM is in operation and experiences an increase in brake 

pipe air flow and/or an increase in brake pipe gradient and the movable pointer does not 

return to the limits established in the initial terminal train air brake test within a 

reasonable time, the train crew shall stop the train for inspection and repair leaks, if 

detected. If unable to make repairs the crew should arrange to set out defective cars 

and/or proceed with due caution to the next location where corrective action can be taken; 

20. All participating railroads shall provide FRA a list of locations where calibrations will be 

performed and of locations which will be provided with test orifices. Changed, deleted, or 

additional locations will be reported to FRA within 92 days; and 

21. All personnel involved with the AFM of testing of train’s air brake systems and operating 

such trains must be given training and be aware of and understand the conditions of the 

waiver. 

(MP&E 98-27) Locomotive Handbrakes -Stencil Requirement for Canadian Railroads –

Title 49, CFR, Section 232.10(f)(2) requires that locomotive handbrakes be inspected and 

repaired as often as service requires with the date suitably stenciled or tagged. Transport 

Canada’s Cab Form 22, Item 8(a) includes this same information. The information in Item 8(a) 

of Transport Canada Cab Form 22 satisfies FRA’s requirement of having “the date suitably 

stenciled or tagged.” 
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(MP&E 98-41) Locomotive Brake Cylinder Pressure

To address questions concerning the minimum locomotive brake cylinder pressure required by 

the Federal regulations, the following guidance applies. 

Section 229.55(c) states: 

The minimum brake cylinder pressure shall be 30 pounds per square inch. 

Section 232.10(n)(8) states: Air pressure regulating devices must be adjusted for the following 

pressures: Self-lapping portion for independent air brake (full application pressure) 30-50 

pounds. These regulations were written when cast iron brake shoes were the standard and the 

brake cylinder relay air valve delivered 100 percent of the control pressure to the brake cylinders. 

With the advent of the high friction composition brake shoe, various relay valves have been used 

depending on whether the rigging was designed for cast iron or composition shoes. To best 

match the stop distance of cast iron, a two-step relay valve is used for composition shoes. One 

level is used for the automatic brake where speeds are generally above “switching” speeds and a 

higher level for the independent brake which is normally used in switching. By tailoring the relay 

valve to the locomotive, a standard independent brake valve setting can be used universally on a 

railroad. This setting is usually 45 psi. The resulting brake cylinder pressure may vary 27 psi 

(with a 60 percent relay) to 72 psi (with a 160 percent relay). The 60 percent relay valves (J-46 

or J-64) are normally found on older locomotives which were converted from cast iron shoes 

with clasp rigging to composition shoes with clasp rigging. FRA considers such locomotives to 

be in compliance with the regulations. 

(MP&E 98-55) Brake Hoses on Cars Equipped with 15" End-of-Car Cushioning Units 

It has been brought to FRA’s attention that some freight cars have undergone modifications that 

includes the installation of a 15" end-of-car cushioning unit, which if not properly installed and 

maintained, can develop a crimped brake hose condition. Often when the draft system is 

converted or improperly maintained, brake hose free play can be reduced, thus causing the brake 

hose to bind in either full buff or full draft positions. 

Inspectors need to be vigilant for signs of brake hose deterioration, especially on cars with 

modified draft systems. If such conditions are found, immediately report them to the railroad. 

Also forward these findings to the Regional MP&E Specialist, so data can be collected to 

determine if a widespread problem exists with a specific series of cars. See FRA Safety 

Advisory 2008-01 at the end of this section. 

(MP&E 98-56) Sloan Model 3050-A and 3200-A Angle Cocks 

Sloan Model 3050-A and 3200-A Angle Cocks have caused injuries to several railroad 

employees. Several railroad employees have experienced personal injury when a Sloan angle 

cock handle and ball assembly forcefully flew apart, from train line pressure, when turned past 

the prescribed closed position due to a broken body stop (a.k.a. mechanical stop) for the handle. 

FRA contacted the AAR regarding this safety hazard. In response, AAR re-issued instructions 
Motive Power and Equipment Compliance Manual 

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for the proper handling/repairing of Sloan Model 3050-A and 3200-A Angle Cocks 

(Maintenance Advisory, (c-8502) MA-27, dated March 14, 1996). 

During routine inspections, all field personnel should be alert to the potential safety hazard and 

verify that all angle cocks have an effective body stop for the handle. 
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Guidance on truck mounted brakes and indicators

Guidance regarding procedures to follow when truck mounted brakes and indicators shown 

below are not within the required limits. Example: At Class I, Class IA, yard inspections with 

brakes applied, repair track, etc... 

How to View Piston Travel Indicators

On Cars with TMX Truck Mounted Brakes

Figure 16: TMX truck mounted brake assembly 

TMX Truck Mounted Brake assembly

As you can see in Figure 16, the TMX Truck mounted brake assembly is completely 

independent of the truck bolster and is attached by means of our brake head end paddles into the 

side frame brake beam guide slots. As you will also see the brake cylinder is mounted to one of 

the brake beams towards the center of the truck bolster with the hand brake lever, (on trucks 
Motive Power and Equipment Compliance Manual 

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connected to the hand brake), cylinder lever, automatic slack adjuster, and return push rod 

connected to the transfer lever of the second brake beam. 

Figure 17: Piston travel indicator arrow is mounted to the piston rod (brake applied) 

In Figure 17 you will see the piston travel indicator arrow mounted to the cylinder piston rod. 

When brakes are applied this arrow passes in front of a piston indicator bracket attached to the 

cylinder non pressure head. As the piston extends Figure 17 illustrates that brakes are applied as 

indicated by the arrow location between the two vertical edges of the bracket window. 
Federal Railroad Administration 

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Figure 18: Piston travel indicator arrow (brake is released) 

When the brakes are released this arrow will be located out of the bracket window closer to the 

cylinder as shown in Figure 18. 

Figure 19: TMX piston travel indicator inspection 
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Figure 20: TMX piston travel indicator inspection 

TMX piston travel indicators can best be observed by looking through the windows next to the 

spring nest in the side frame of standard AAR three piece trucks just over the brake heads ahead 

of the cylinder and towards the center of the truck. See Figure 19 and Figure 20. 
Federal Railroad Administration 

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Motive Power and Equipment Compliance Manual 

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Chapter 12

Passenger Equipment Safety Standards 

Part 238

Introduction

The Federal Railroad Administration added Part 238 containing Passenger Equipment Safety 

Standards (PESS) on May 12, 1999 (64 FR 25540) and issued responses to petitions for 

reconsideration through final rules published on July 3, 2000, April 23, 2002, and June 25, 2002 

(65 FR 41284, 67 FR 19970, and 67 FR 42892, respectively). On October 19, 2006, FRA 

published a final rule that addressed various mechanical issues relevant to the manufacture, 

efficient utilization, and safe operation of passenger equipment and trains that have arisen since 

the issuance of the PESS rule (71 FR 61836). Additionally, on February 1, 2008, and January 8, 

2010, FRA published final rules further amending Part 238 to enhance and add requirements 

regarding Passenger Train Emergency Systems (PTES) (73 FR 6370) and enahance requirements 

for the structural strength of the front end of cab cars and multiple-unti locomotives (75 FR 

1180), respectively. The original PESS regulation became effective on July 12, 1999. The 

guidance contained in this section of the compliance manual addresses specific issues or 

questions raised since the issuance of these rules. For information or guidance of a specific 

provision not covered in this manual, the preamble discussions contained in the publications 

noted above should be consulted and reviewed, along with any other related chapters in FRA’s 

compliance manuals (e.g., Chapter 15 of the Operating Practices Manual, which includes 

guidance regarding the PTES final rule). FRA intends to update this portion of the manual on a 

regular basis to include any new issues or guidance concerning any of the PESS provisions. 

The following provides guidance to be used by Federal and State inspectors when conducting 

inspections of passenger equipment for compliance with Federal laws and regulations. Although 

Inspectors have enforcement discretion regarding whether or not to recommend a defect for 

violation, it is important that agency enforcement policies be adhered to by every inspector when 

conducting inspections, so that uniformity of enforcement activity is achieved. 

The procedures provided in both this manual and FRA’s General Manual should be observed 

when assessing the need for appropriate corrective actions regarding noncompliance with the 

passenger equipment safety standards. It should be noted that there is significant interplay 

between the provisions contained in this part and provisions contained in other parts of the 

Federal regulations. These include: the Locomotive Safety Standards (LSS) in Part 229; the 

Safety Appliances Standards in Part 231; and the Passenger Train Emergency Preparedness 

regulations contained in Part 239. When an MP&E Inspector determines that a defect exists on 

passenger equipment which may not be conducive to safe operation, the inspector must decide if 

the defect— 

 Is a Part 238 defect. 

 Should be documented on the F6180.96 - Inspection Report. 

 Warrants the issuance of a violation. 
Motive Power and Equipment Compliance Manual 

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 Warrants the issuance of a Special Notice for Repairs under Part 216. 

 Should be reported to the railroad as an unsafe condition, not encompassed in the Federal 

regulations. 

The following discussion addresses various issues that have arisen during the implementation of 

the passenger equipment safety standards and provides guidance on the enforcement of those 

issues. 

Part 238, Subpart A—General

238.3 Applicability. 

Guidance 

The requirements of Part 238 do not apply to tourist, scenic, historic, or excursion operations 

even if they operate over the general railroad system. Transportation of passengers to a 

particular destination is not the principal purpose of a tourist or scenic railway. The 

requirements also do not apply to circus trains. 

238.5 Definitions.

For the complete list of definitions, please refer to the 49 CFR Part 238, § 238.5. The following 

definitions are the most relevant or more often inquired in this section for purposes of conducting 

an MP&E inspection: 

Actuator means a self-contained brake system component that generates the force to apply the 

brake shoe or brake pad to the wheel or disc. An actuator typically consists of a cylinder, piston, 

and piston rod. 

The actuator moves as a direct action of the brake piston when applying retarding force or from a 

load cell that reads brake shoe pressure. 

Brake indicator means a device, actuated by brake cylinder pressure, which indicates whether 

brakes are applied or released. 

This device is operated by means other than directly off the piston movement, such as pressure 

switches located in the brake pipe or low pressure head. 

Calendar day means a time period running from one midnight to the next midnight on a given 

date. 

This is the same as a calendar day inspection required in the Railroad Locomotive Safety 

Standards. One inspection for each day, or part of a day, the equipment is used in service. 
Motive Power and Equipment Compliance Manual 

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Locomotive, MU means rail rolling equipment self-propelled by any power source and intended 

to provide transportation for members of the general public; however, this term does not include 

an MU locomotive propelled by steam power unless it is used to haul an intercity or commuter 

passenger train. 

Unlike the definition in the Railroad Locomotive Safety Standards, MU in this rule includes MU 

passenger locomotives powered by a number of sources. 

Passenger car means rail rolling equipment intended to provide transportation for members of 

the general public and includes a self-propelled car designed to carry passengers, baggage, mail, 

or express. This term includes a passenger coach, cab car, and an MU locomotive. In the 

context of articulated equipment, “passenger car” means that segment of the rail rolling 

equipment located between two trucks. This term does not include a private car. 

Passenger car, as defined, includes MU locomotives. Thus, whenever the term “passenger car” 

is used, then MU locomotives are included unless expressly excluded. MU locomotives, as well 

as traditional locomotives, remain under the requirements found in Part 229 with the exception 

of those items in Part 238 not expressly addressed in Part 229, such as deadman pedals or 

alerters. MU locomotives are required to be inspected by a qualified maintenance person 

(QMP). Such an inspection may satisfy the requirements for a locomotive daily inspection under 

Part 229, if it includes all items addressed in that part. However, a locomotive daily inspection 

under Part 229 will not satisfy the need for the exterior mechanical inspection required by the 

Passenger Equipment Safety Standards unless it is performed by a QMP and also covers all 

components and parts addressed in Part 238. If a traditional locomotive receives a daily 

inspection under Part 229 by an employee other-than a QMP, then those items that are not 

covered in the Railroad Locomotive Safety Standards (Part 229) but are addressed in the 

Passenger Equipment Safety standards (Part 238) must be re-inspected by a QMP (ex: dynamic 

brake, alerter/deadman pedal). 

Power car means a rail vehicle that propels a Tier II passenger train or is the lead vehicle in a 

Tier II passenger train, or both.

Power cars (whether occupied or unoccupied) are considered to be Passenger Equipment and 

must comply with the inspection, testing, and maintenance (ITM) requirements in § 238.503. 

FRA review and approval of the railroad’s ITM program is contingent on it meeting or 

exceeding the requirements of the Locomotive Inspection Act for power cars. 

Private Car means rail rolling equipment that is used only for excursion, recreational, or private 

transportation purposes. A private car is not a passenger car. 

Private railroad cars operating in an intercity passenger (e.g., Amtrak, Alaska Railroad) or 

commuter train are regulated under Part 238 as a type of “passenger equipment” (see paragraph 

(1)(v) of the definition of this term in § 238.5). Private cars are subject to a number of 

requirements in Part 238, principally to protect the safety of the passenger trains hauling the 

private cars and the railroad employees handling the cars. These include requirements for daily 

(§ 238.303) and periodic (§ 238.307) exterior mechanical inspections, air brake inspections 
Motive Power and Equipment Compliance Manual 

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(§§ 238.309 and 238.311), safety appliances (§ 238.229, referencing Part 231), and suspension 

system safety (§ 238.227). 

Passenger cars (which, by definition, do not include private cars) are subject to numerous, 

additional requirements, including requirements for daily interior inspections (§ 238.305), 

interior fittings (§ 238.233), fire safety (§ 238.103), and emergency lighting (§ 238.115). Private 

cars are not directly subject to fire safety requirements or emergency preparedness requirements 

in Part 239. Nonetheless, passenger railroads that haul private cars need to consider the possible 

presence of such private cars when they are developing their fire safety analyses and Part 239 

emergency preparedness plans. 

FRA notes that Amtrak requires a detailed annual inspection of the private cars it operates 

(Amtrak Form MAP PC-1), as well as a comprehensive running gear inspection and overhaul of 

all private cars over 40 years old (Amtrak Form MAP PC-2). FRA considers a completed 

Amtrak MAP PC-1 to meet the requirements for records of periodic maintenance for private cars 

required in § 238.307. 

If a private car is not being operated in an intercity passenger or commuter train, it is still subject 

to various requirements, depending on the nature of the railroad operation. For instance, a 

private car operating in a freight train is subject to the air brake maintenance requirements in 

Appendix B of Part 232 and the safety appliance standards of Part 231. In addition, private cars 

are subject to the Safety Glazing Standards of Part 223, unless the cars are “ historical” or 

“antiquated” (i.e., built in 1945 or earlier). 

Private Railcars Regulatory Compliance: Q&A

Must private railcars follow the same regulations as other passenger cars in terms of 

safety? Do the private railcar owners need to report to FRA and does FRA ever inspect 

their equipment/records?

In general, private railroad cars (or private cars) operating in Amtrak or commuter trains are 

regulated under the Part 238, as passenger equipment, which includes passenger cars

transporting the general public, locomotives, baggage cars, mail cars, and private cars. As such, 

private cars are subject to the requirements that apply to all passenger equipment, including 

requirements for daily and periodic exterior mechanical inspections, air brake inspections, safety 

appliances (sill steps, handholds and handrails), suspension system safety, and wheel 

inspections--which are all items that if not in compliance with the safety regulations could 

endanger the safety of the passenger train hauling the private car. 

Passenger cars (which do not include private cars) are subject to additional requirements, such 

as a daily interior inspection, interior equipment fastening requirements, fire safety standards, 

and emergency signage requirements. However, a passenger railroad that regularly hauls private 

cars needs to consider the possible presence of a private car in their trains when they are 

developing their fire safety analyses and emergency preparedness plans. 
Motive Power and Equipment Compliance Manual 

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In addition, Amtrak requires a detailed annual inspection of the private cars it operates, and a 

comprehensive running gear inspection and overhaul of all private cars over 40 years old. 

In general, if a car is not being operated in Amtrak or commuter train, it is still subject to the air 

brake maintenance requirements in Part 232 and the safety appliance standards of Part 231 (sill 

steps, handholds, handrails, uncoupling levers and handbrake and/or statute (Title 49 of the 

United States Code). It is also subject to the glazing requirements of Part 223, unless it is 

historic or antiquated (i.e., built before 1945) and used only for excursion, educational, 

recreational purposes or private transportation purposes (see § 223.3(b)(3)). 

Private railcar owners do not have to report railcar maintenance and/or other mechanical-related 

information to FRA. However, they could be held responsible for a failure to maintain proper 

records, which is subject to inspection and review by FRA Motive Power and Equipment 

(MP&E) inspectors. The operating railroads have the primary responsibility for operating 

compliant equipment in their trains, and that is where FRA’s inspectors generally focus their 

attention. Subsequently, if a railroad has any questions as to compliance, they often follow up 

with the owners of the equipment so as to avoid liability from FRA, which helps to ensure 

compliance with FRA regulations. 

§ 238.9 Responsibility for compliance.

This section establishes two levels of liability depending on the nature of the defect or inspection 

for which noncompliance with this part is being alleged. A strict liability standard is applied to 

non-conformity with any of the safety appliance and power brake provisions of Part 238, 

including the inspection provision addressing such components. Paragraph (a)(1) makes clear 

that a railroad may not use, haul, permit to be used or hauled on its line, offer in interchange, or 

accept in interchange any train or equipment with one or more conditions not in compliance with 

Part 238’s power brake or safety appliance provisions or the involved inspection provisions. A 

reasonable person standard is applied to all other conditions not in compliance with Part 238, 

other than the safety appliance and power brake provisions. Paragraph (a)(2) makes clear that 

for other than safety appliance or power brake defects, a railroad may not use, haul, permit to be 

used or hauled on its line, offer in interchange, or accept in interchange any train or equipment 

with one or more conditions not in compliance with Part 238 if the railroad has actual knowledge 

of the facts giving rise to the violation, or a reasonable person acting in the circumstances and 

exercising reasonable care would have that knowledge. 

Strict liability applies to the use or haul of equipment with defective safety appliances. If a piece 

of passenger equipment is discovered with a defective safety appliance or power brake and it is 

not being used or hauled pursuant to the statutory provisions contained in 49 U.S.C. § 20303 and 

the movement of defective equipment provision of § 238.15, appropriate enforcement action 

must be taken. If a railroad is unaware of the existence of a defective condition, it cannot be 

considered to be properly hauling the equipment for repairs under either the statute or § 238.15. 

Knowledge of the defect need not be established. Inspectors are expected to use sound judgment 

together with the guidance outlined in the General Manual and Chapter 3 of this manual when 

deciding whether the issuance of a violation report is appropriate. 
Motive Power and Equipment Compliance Manual 

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Reasonable person liability standard is a somewhat lower standard of liability than the strict 

liability standard noted above. Under this standard a railroad subject to this part is liable only if 

it knew, had noticed, or should have known of the existence of either a defective condition on the 

equipment or the failure to inspect and test the equipment as prescribed in this part. Thus, when 

seeking a violation of a requirement or provision, other than a safety appliance or power brake 

requirement, FRA must establish that the railroad had actual knowledge of the condition or a 

reasonable person exercising reasonable care would have such knowledge. Consequently, a 

violation report must discuss the inspector’s basis for finding that the railroad knew or 

reasonably should have known of the presence of the defective condition. Inspectors should be 

as specific as possible when detailing this information. 

Paragraph (b) of this section states that in order to establish a violation, FRA must prove that the 

equipment was “used or hauled” in defective condition. Thus, evidence of an actual “haul” of 

the defective equipment in a train is always sufficient to support a violation. In addition, this 

section makes clear that FRA will consider a piece of equipment “in use” and subject to potential 

civil penalties prior to departure but after a railroad has or should have completed its required 

inspections and is deemed ready for service. Thus, FRA is not necessarily required to wait for a 

car with a defective safety appliance or power brake to depart or engage in an actual “haul” in 

order to assess a violation. If inspectors rely on the above interpretation, the violation report 

must establish that the railroad had completed all necessary inspections capable of discovering 

the alleged defective condition. Therefore, evidence must be included in the violation report 

which establishes the inspector’s basis for this finding (be as specific as possible, include names, 

if available). Note: This is added enforcement flexibility and may not be the appropriate 

approach in many situations; in many circumstances the best approach is still to establish actual 

use or movement of the equipment. 

Paragraph (c) clarifies FRA’s position that the requirements of this part are applicable not only to 

any railroad subject to the part but also to any person, as defined in §238.5, that performs any 

function required by Part 238. Although various sections of the regulation address the duties of a 

railroad, FRA intends that any person who performs any action on behalf of a railroad or any 

person who performs any action covered by the rule is required to perform that action in the 

same manner as required of a railroad or be potentially subject to FRA enforcement action. 

§ 238.15 Movement of passenger equipment with power brake defects. 

Guidance 

 

Paragraph (b) provides that any equipment that is found with a defective air brake during a Class 

I or IA brake test may only be moved in a non-revenue train (i.e., without passengers) after 

meeting all additional conditions for the movement of passenger equipment with brakes that 

became defective en route. That is, the train movement must comply with the applicable 

operating restrictions in paragraphs (d) and (e) of this section, and the defective equipment must 

be tagged (or information recorded) pursuant to paragraph (c)(2) of this section. Secondary 

braking systems, such as dynamic braking, may be continued in service under the conditions 

found in § 238.303(e)(15)(i) and (ii). 
Motive Power and Equipment Compliance Manual 

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When railroads move equipment with brakes that become defective en route, inspectors should 

consider more than just the equipment conditions to decide if it is safe to unload passengers at 

the next station. They should look at the location as to the safety of passengers, overloading 

equipment, weather, and a number of other concerns. Railroads should not be cited for 

exercising good judgment to ensure the safety of their passengers. 

 

If the train reaches its final destination and all passengers have detrained, the railroad must then 

move the equipment for repair while out of service and without passengers. This includes trains 

that operate to a final destination where the crew would normally change ends and then perform 

a Class II brake test to operate the equipment towards a repair facility, the return trip must be 

conducted while out of service and without passengers. 

Paragraph (e). – This paragraph places operating restrictions on passenger trains with 

“completely inoperative” power brakes on the front or rear unit. Coupler mates or similar 

equipment that are physically joined by a trailer or container operated at the rear of a passenger 

train that has a braking problem resulting in a truck brake system being cut out does not 

constitute “completely inoperative” brakes at the rear of the train unless both trucks are cut out. 

238.17 Movement of passenger equipment with other than power brake defects. 

The off-site QMP could make required determinations when defective running gear is involved 

and report via radio or telephone without being on the scene. 

Part 238, Subpart B—Safety Planning and General Requirements

238.109 Training qualification, and designation program. 

Paragraph (a). Beginning on January 1, 2002, each railroad shall have adopted a training, 

qualification, and designation program for employees and contractors that perform any of the 

inspections, tests, or maintenance required by this part, and shall have trained such employees 

and contractors in accordance with the program. 

Guidance 

If the railroad uses a contractor or another railroad to provide required training the railroad 

should adopt the training plan being used and keep good records. FRA believes that 

maintaininggood records is the cornerstone of the training requirements. 

The tests, inspections, and maintenance required to be performed by a QMP is identified in each 

section where it is required. An example would be when a person who is QMP- qualified to 

perform an exterior calendar day mechanical inspection (§ 238.303) finds a wheel with a 

condemnable defect. After the condition is reported, the car moves to a wheel true machine for 

repair. While the rule requires that the inspector be a QMP to perform the exterior calendar day 

mechanical inspection, there is no such requirement for the wheel true operator, and no 

requirement that a QMP inspect the equipment upon release from the wheel true facility. 
Motive Power and Equipment Compliance Manual 

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Paragraph (b)(8). Require supervisors to complete the program that covers the employees whom 

they supervise, including refresher training. 

Guidance 

Supervisors, as discussed in the requirement are first-line supervisors of QMPs, and these 

supervisors must complete a program that covers the same material as the QMP employees they 

supervise. This requirement is only for the first-line supervisor. 

Paragraph (b)(10). Designate in writing that each employee and contractor has the knowledge 

and skills necessary to perform the safety-related tasks that are part of his or her job. 

Guidance 

Employees are not required to carry a card that lists their qualifications, but railroads must 

maintain a list of its employees’ qualifications and be able to provide that information to FRA 

upon request. 

238.119 Rim-stamped straight-plate wheels. 

Paragraph (a)(1). Except as provided in paragraph (a)(2) of this section, on or after November 8, 

1999, no railroad shall place or continue in service any vehicle, other than a private car, that is 

equipped with a rim-stamped straight-plate wheel if a brake shoe acts on the tread of the wheel 

for the purpose of slowing the vehicle. 

Guidance 

This is only for rim-stamped straight-plate wheels with tread braking, this does not include hubstamped straight-plate wheels. 

Part 238, Subpart D—Inspection, Testing, and Maintenance Requirements 

for Tier I Passenger Equipment

238.303 Exterior calendar day mechanical inspection of passenger equipment. 

Paragraph (a). Except as provided in paragraph (f) of this section, each passenger car and each 

unpowered vehicle used in a passenger train shall receive an exterior mechanical inspection at 

least once each calendar day that the equipment is placed in service. 

Guidance 

The requirement applies to passenger cars. As defined, that includes MU passenger locomotives 

and all other equipment hauled in a passenger train. 

A calendar day inspection (or “daily inspection”) is required for any calendar day the passenger 

equipment is used in service. A calendar inspection is not governed by the amount of time the 
Motive Power and Equipment Compliance Manual 

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equipment was used. A passenger car that arrives at 12:20 in the morning on any given day 

would be required to receive a calendar day mechanical inspection on that day. 

If a long-haul passenger car receives a daily mechanical inspection and departs, and some time 

after midnight the car becomes defective and is set out, the railroad would not be responsible to 

perform a daily inspection for the day that it was used in service and set out, but would have to 

perform an inspection prior to placing the car into another train or before moving the car for the 

purpose of repair. 

The daily inspection of MU locomotives and control car locomotives performed under the 

requirements of a locomotive daily inspection (§ 229.21) does not fulfill the requirements for a 

daily mechanical inspection of passenger equipment unless performed by a QMP qualified for 

that inspection. Conventional locomotives can be inspected by people the railroad deems 

qualified (§ 229.21(c)) who are not QMPs with the exception of those items specifically 

addressed in the Passenger Equipment Safety Standards not covered in the Locomotive Safety 

Standards, such as dynamic brakes and alerters. 

238.305 Interior calendar day mechanical inspection of passenger cars. 

Paragraph (c)(5). The words “Emergency Brake Valve” are legibly stenciled or marked near 

each brake pipe valve or shown on an adjacent badge plate. 

Guidance 

The required language "Emergency Brake Valve" is preferred, but inspectors should use good 

judgment when encountering similar verbiage on the stencil or marking, as a large number of 

these valves are marked “Brake Emergency Use Only.” Inspectors should take no exception to 

this or other markings that meet the intent. 

238.307 Periodic mechanical inspection of passenger cars and unpowered vehicles used in 

passenger trains. 

Paragraph (a). Railroads shall conduct periodic mechanical inspections of all passenger cars and 

all unpowered vehicles used in a passenger train as required by this section or as warranted and 

justified by data developed pursuant to paragraph (a)(2) of this section. A periodic inspection 

conducted under part 229 of this chapter satisfies the requirement of this section with respect to 

the features inspected. 

Guidance 

The requirement applies to passenger cars. As defined, that includes control car locomotives and 

MU passenger locomotives. Those items of inspection that are performed as part of the 92-day, 

annual, or biannual inspection required as part of the locomotive safety standards are not 

required to be included in the periodic under the passenger equipment periodic inspection. 
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Paragraph (b). Each periodic mechanical inspection required by this section shall be performed 

by a qualified maintenance person. 

Guidance 

The inspection of the equipment must be performed by a QMP. If a defect has been identified, it 

must be repaired before the equipment is returned to service. There is no requirement that a 

QMP make the repairs or re-inspect the equipment when repairs are completed. 

 

Paragraph (c). The periodic mechanical inspection shall specifically include the following 

interior and exterior mechanical components, which shall be inspected not less frequently than 

every 184 days. At a minimum, this inspection shall determine that: 

Guidance 

The 184 day requirement was issued after the 180 day requirement contained in § 239.107(b)(2) 

and supersedes that requirement. 

Paragraph (d). At an interval not to exceed 368 days, the periodic mechanical inspection shall 

specifically include inspection of the following... 

.... 

(2) The hand or parking brake as well as its parts and connections, to determine that they are in 

proper condition and operate as intended. The date of the last inspection shall be either entered 

on Form FRA F 6180-49A, suitably stenciled or tagged on the equipment, or maintained 

electronically provided FRA has access to the record upon request. 

Guidance 

(MP&E 07-02) Druing the drafting of the rule text, the requirements for testing and recording 

were copied from similar requirements applicable only to locomotives. As a results, the form 

specified in the rule, Form F 6180.49A (Blue Card), is a locomotive form. However, FRA did 

not intend to limit use of an onlobar record to a Blue Card for keeping test information under this 

section, especially for equipment that is not a locomotive. Therefore, FRA makes clear that the 

onboard record may be kept in any manner chosen by the railroad as long as it contains all the 

required information and is legible. The record does not havbe to be a Blue Card. Further, 

railroads may also stencil the information or keep the information electronically, as provided in 

the section. 

238.309 Periodic brake equipment maintenance. 

Guidance 

Locomotive air dryers. 
Motive Power and Equipment Compliance Manual 

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Locomotive air dryers (“air dryers”) are not specifically addressed by Federal safety laws (see 49 

CFR Part 229 and 49 U.S.C. § 20103), nor has FRA determined that air dryers are an 

appurtenance to the locomotive for purposes of 49 CFR § 229.7. Because air dryers are not 

addressed by Federal safety laws, no violations should be taken for defective air dryers. 

In a number of the waivers granted by FRA’s Railroad Safety Board (“Board”) to extend the 

intervals between brake maintenance (similar to the cleaning, repairing, and testing commonly 

referred to as COT&S) on both freight (49 CFR § 229.29, Biennial tests) and passenger (49 CFR 

§ 238.309, Periodic brake equipment maintenance), the Board required a functioning air dryer as 

a condition of the waiver. If a locomotive covered by a waiver that requires a functioning air 

dryer is beyond the current brake maintenance interval in the regulation, and is found to have a 

defective air dryer, the locomotive would be noncompliant under 49 CFR § 229329 or 49 CFR § 

238.309 because of the overdue brake maintenance, and not for the defective air dryer. The 

waivers do not explain how FRA will determine whether an air dryer is defective. Violation 

reports must explain the basis for the inspector’s determination that the air dryer is defective, and 

must include a copy of the applicable waiver with the report. As a note, inspectors should not 

rely only on the air dryer’s color indicator to make the determination. 

238.311 Single car test. 

Paragraph (b). Each single car test required by this section shall be performed by a qualified 

maintenance person. 

Guidance 

As in the previously discussed inspection requirements above (see §§ 238.109 and 238.307), the 

single car test must be performed by a QMP. It should be noted that, as also discussed above, the 

regulation does not require associated work, such as removal or replacement of valves, to be 

performed by a QMP or to be re-inspected by a QMP after repairs have been completed. 

Amtrak requested and was granted approval of an alternate standard for performing single car 

tests of Talgo equipment. This request was assigned docket number FRA-2003-16666.” A copy 

of the decision letter is available in the section of this compliance manual titled “MP&E 

Waivers.”. 

The American Public Transportation Association (APTA) requested and was granted approval of 

an alternate standard for performing single car tests of passenger equipment. The approval 

allows the railroad to use the original APTA Code of Test identified in the Passenger Equipment 

Safety Standards or the alternate test code dated March 24, 2003, which allows the test to be 

performed at the pressure at which the brake system is operated. Railroads are free to use either 

test as needed. This request was assigned docket number FRA-2005-20053,” A copy of the test 

code is available from APTA at: 

http://www.aptastandards.com/PublishedDocuments/PublishedStandards/PRESS/tabid/85/Defaul

t.aspx. 
Motive Power and Equipment Compliance Manual 

12 – 12 

§ 238.313 Class I brake test. 

The requirement to conduct a Class I brake test in paragraph (a) of this section includes all 

passenger cars that are not self-propelled (so as to exclude MU locomotives and other selfpropelled vehicles) and passenger equipment being moved by a passenger railroad, with the 

exception of equipment being moved in compliance with § 238.15, Movement of passenger 

equipment with power brake defects. This includes mail trains and passenger equipment without 

passengers on board that is being moved by a passenger railroad. FRA would consider these 

cars to be either in revenue service or designed to carry passengers. 

Paragraph (a). Each commuter and short-distance intercity passenger train shall receive a Class I 

brake test once each calendar day that the train is placed or continues in passenger service. 

Guidance 

If a train is used in service on any given day, regardless of time used, it must receive a Class I 

brake test. This test can be performed before the service begins or upon completion of service. 

Paragraph (d). Each Class I brake test shall be performed by a qualified maintenance person. 

Guidance 

The Class I brake test must be performed by a QMP qualified for that particular test. The test 

may use a non-QMP to manipulate the brake valves during the performance of the test. 

Paragraph (f)(7). Brake pipe leakage does not exceed 5 pounds per square inch per minute if 

leakage will affect service performance; 

Guidance 

Brake pipe leakage may not exceed 5 pounds per square inch per minute, but does not need to be 

tested unless the leak will affect the operation of the train brakes. Accordingly, any violation 

reports based on this section must include an explanation of how the leakage will affect service 

performance of the brakes. 

Paragraph (g)(14). If the equipment is provided with a brake indicator, the brake indicator 

operates as intended; and 

Guidance 

Most passenger cars and MUs are equipped with indicator lights, but some are equipped with 

multiple indicators located on each side of the equipment. In such cases, only one set of these 

indicators per side of car must work to be in compliance. 

238.315 Class IA brake test. 
Motive Power and Equipment Compliance Manual 

12 – 13 

Paragraph (a)(1)(iii). The train has not been disconnected from a source of compressed air for 

more than four hours since the performance of the Class I brake test; and 

Guidance 

The minimum pressure of ground compressed air to be considered sufficient is 60 psi. 

Paragraph (b). A commuter or short-distance intercity passenger train that provides continuing 

late night service that began prior to midnight may complete its daily operating cycle after 

midnight without performing another Class I or Class IA brake test. A Class I or Class IA brake 

test shall be performed on such a train before it starts a new daily operating cycle. 

Guidance 

Some commuter systems operate service beyond midnight, and the requirement to perform a 

Class IA prior to the first morning departure was written to make clear that a train is not required 

to be stopped during its operating cycle in order to receive a Class I or Class IA brake test prior 

to its first departure of a calendar day. This provision does not, however, relieve a railroad from 

its responsibility under § 238.313 to perform a Class I brake test on each calendar day that the 

train is in use—the train operating past midnight must receive a Class I brake test someimte on 

each of the two days it is in use. . Inspectors should use good judgment when determining if a 

train requires a Class IA brake test prior to the first morning departure. In contrast to the trains 

that are not operated through the night (for which the railroad has plenty of time to conduct 

required tests), the trains that operate throughout the night may only lay up for short periods of 

time, an hour or two, and requiring a test before the first morning departure may not be 

practicable. 

Paragraph (e). Except as provided in § 238.15(b), a railroad shall not use or haul a passenger 

train in passenger service from a location where a Class IA brake test has been performed, or was 

required by this part to have been performed, with less than 100 percent operative brakes. 

Guidance 

See § 238.315 and the earlier discussion of the conditions for the movement of passenger 

equipment with power brake defects for repair. Failure to observe any condition for the 

movement of such equipment will deprive the railroad of the benefit of the movement-for-repair 

provision and make the railroad and any responsible individuals liable for a civil penalty under 

this section. 

Paragraph (f). A Class IA brake test shall be performed at the air pressure at which the train’s air 

brakes will be operated and shall determine and ensure that: 

Guidance 
Motive Power and Equipment Compliance Manual 

12 – 14 

The Class IA brake test does not require trains equipped with electro-pneumatic brakes to have 

the electro-pneumatic feature tested. This is only required at the Class I test. If the electropneumatic feature is defective and is cut out, it is not considered defective until the Class I is 

performed, and the equipment may be continued in service. 

Paragraph (f)(1). Brake pipe leakage does not exceed 5 pounds per square inch per minute if 

brake pipe leakage will affect service performance; 

Guidance 

Brake pipe leakage may not exceed 5 pounds per square inch per minute but does not need to be 

tested unless the leak will affect the operation of the train brakes. Accordingly, any violation 

reports based on this section must include an explanation of how the leakage will affect service 

performance of the brakes. 

Paragraph (f)(3). For MU locomotives that utilize an electric signal to communicate a service 

brake application and only a pneumatic signal to propagate an emergency brake application, the 

emergency brake application functions as intended[;] 

Guidance 

Railroads are not required to physically test the deadman pedal or other emergency control 

devices during the Class IA or II brake test with the exception of electric MU equipment that 

uses an electric signal to communicate a service application and uses only a pneumatic signal for 

an emergency application; such MU equipment must have the emergency application of its 

emergency control devices tested to determine that the devices function as intended. Railroads 

are required to test the deadman pedal or other emergency control devices during the Class IA 

brake test. 

§ 238.317 Class II brake test.

The Class II brake test does not require trains equipped with electro-pneumatic brakes to have 

the electro-pneumatic feature tested; this is only required at the Class I test. If the electropneumatic feature is defective and is cut out, it is not considered defective until the Class I is 

performed, and the equipment may be continued in service. 

Paragraph (a)(5). When an operator first takes charge of the train, except for face-to-face relief. 

Guidance 

Face-to-face relief would include a QMP, or other persons participating in the Class I brake test, 

relieving a crewmember, as well as a crew relieving another crew. 

Paragraph (d)(1). The brakes on the rear unit of the train apply and release in response to a 

signal from the engineer's brake valve or controller of the leading or controlling unit, or a gauge 
Motive Power and Equipment Compliance Manual 

12 – 15 

or similar device located at the rear of the train or in the cab of the rear unit indicates that brake 

pipe pressure changes are properly communicated at the rear of the train; 

Guidance 

If the railroad places a device at the rear of the train that provides a visual indication of changes 

in brake pipe pressure, and this indication can be viewed from the front of the train, it fulfills this 

requirement to test. 

Paragraph (d)(2). For MU locomotives that utilize an electric signal to communicate a service 

brake application and only a pneumatic signal to propagate an emergency brake application, the 

emergency brake application functions as intended. 

Guidance 

Railroads are not required to physically test the deadman pedal or other emergency control 

devices during the Class IA or II brake test with the exception of electric MU equipment that 

uses an electric signal to communicate a service application and uses only a pneumatic signal for 

an emergency application; such MU equipment must have the emergency application of its 

emergency control devices tested to determine that the devices function as intended. Railroads 

are required to test the deadman pedal or other emergency control devices during the Class IA 

brake test. 

§ 238, Subpart F—Inspection, Testing, and Maintenance Requirements 

for Tier II Passenger Equipment

 

§ 238.503 Inspection, testing, and maintenance requirements 

Paragraph (d)(3). Trains that miss a scheduled Class I brake test or mechanical inspection due to 

a delay en route may proceed to the point where the Class I brake test or mechanical inspection 

was scheduled to be performed. 

Guidance 

Inspectors need to be very careful in applying this provision. In FRA’s view, a “delay en route” 

can only occur between terminus points. Boston and Washington would be considered “terminus 

points,” since at those locations the trains lay-up and are given new train symbols. FRA believes 

this approach is consistent with the rule’s intent. Thus, if an Acela train is delayed en route it 

may proceed to either Washington or Boston, but may not be turned if it cannot complete a 

return trip within the provided time frame. 
Chapter 13 

Passenger Train Emergency Preparedness, Part 239 

(Written guidance is currently being developed and will be published in the near future.) 
14 - 1

Chapter 14 

Reflectorization of Rail Freight Rolling Stock 

Part 224 

Introduction

The Federal Railroad Administration published the final rule for Reflectorization of Rail Freight 

Rolling Stock, 49 CFR Part 224 on October 28, 2005. 

The effective date of the rule as published in the Federal Register, Vol. 70, No. 208, is 

November 28, 2005. The purpose of the rule is to require the application of retroreflective tape 

material to the sides of freight rolling stock (freight cars and locomotives) to enhance the 

visibility of trains during times of limited visibility. 

Years of research and public involvement have been devoted to the issue of making trains more 

visible at road crossings especially when visibility is limited due to weather or night time 

conditions. The rule addresses the need for the reflectorization of rail equipment as well as a 

description of FRA’s research and public outreach efforts aimed at identifying the most effective 

method for implementing a nationwide Reflectorization program. 

The rule provides car owners up to 10 years (see § 224.107, Table 3, for implementation dates) 

in which to apply retroreflective material to their equipment; and locomotive owners 5 years in 

which to equip their locomotives. The rule provides guidelines for the characteristics of the 

material, the dimensions, and the quantity to be applied as well as locations for consistent 

application. 

Guidance

When is retroreflective sheeting required to be applied to freight cars and locomotives 

constructed after January 26, 2006? 

§ 224.107(a)(1) 

Freight cars and locomotives constructed after January 26, 2006, must be equipped with 

retroreflective sheeting before being placed in service. 

When is retroreflective sheeting required to be applied to existing freight cars and 

locomotives that as of October 28, 2005, were not equipped with any retroreflective 

material?

§ 224.107(a)(2)(i) 

Part 224 provides two alternative schedules for the application of the required retroreflective 

material to railroad equipment already in service at the time of the rule’s publication— 
Federal Railroad Administration 

14 - 2 

(1) As applied to freight cars, first, the “default” schedule of § 224.107(a)(2)(i) requires that 

retroreflective sheeting be applied to existing cars (1) when the car is repainted or rebuilt; 

or (2) within nine months (270 calendar days) after the car first undergoes a single car air 

brake test (SCABT) pursuant to § 232.305. Similarly, as applied to locomotives, the 

“default” schedule of § 224.107(b)(2)(i) requires conforming retroreflective sheeting to 

be applied to locomotives not later than nine months after the first biennial inspection 

pursuant to § 229.29 occurring after November 28, 2005. 

(2) Alternatively, §§ 224.107(a)(2)(ii) and (b)(2)(ii) permit freight cars and locomotives to be 

reflectorized on a more individualized and flexible schedule, provided certain conditions 

are met. Specifically, these paragraphs permit freight rolling stock owners (as defined in 

§ 224.5) to opt-out of the default schedule of § 224.107(a)(2)(i) and/or (b)(2)(i) and 

develop and implement their own schedule for reflectorization, provided the owner (1) 

files a “Reflectorization Implementation Compliance Report” with FRA; and (2) 

complies with the implementation schedules in Tables 3 (freight cars) and 4 

(locomotives) of the section. 

It is important to note that because a fleet owner may elect to opt out of the “default” schedule of 

the rule and elect to reflectorize its equipment according to its own plan by filing a 

“Reflectorization Implementation Compliance Report” (Compliance Report), when examining 

equipment subject to Part 224 and constructed on or before January 26, 2006, to determine 

whether that equipment is required to be equipped with conforming retroreflective material, an 

Inspector must first determine if the relevant owner filed a Compliance Report with FRA. 

Moreover, if the owner filed a Compliance Report, a violation could not be pursued for failing to 

equip a specific car or locomotive with reflectorization unless it is shown that the percentage of 

freight cars or locomotives identified in Table 3 and Table 4 of part 224 are not met. 

When is retroreflective sheeting required to be applied to existing freight cars and 

locomotives that as of October 28, 2005, were equipped with at least one square foot of 

retroreflective sheeting? 

§ 224.5 

Provided responsible freight rolling stock owner files a “Reflectorization Implementation 

Compliance Report” with FRA, and the sheeting is not “unqualified retroreflective sheeting” as 

defined in § 224.5, freight cars and locomotives that as of October 28, 2005 were equipped with 

at least one square foot of retroreflective sheeting are grandfathered until November 28, 2015. 

Where can the retroreflective sheeting be applied? 

§ 224.106 Location of retroreflective sheeting. 

Generally, retroreflective sheeting shall be applied along the length of each railroad freight car 

side in the manner provided by a uniform industry standard accepted by the Associate 

Administrator that provides for distribution of material along the length of each car and as close 
Motive Power and Equipment Compliance Manual 

14 - 3 

as practicable to 42 inches above the top of rail. Diagrams are include in § 224.106 as a 

guideline for general applications. 

If retroreflective sheeting is applied in a vertical pattern, at least one 4x36 inch strip or two 4x18 

inch strips, one above the other, shall be applied as close to each end of the car as practicable. 

Between these two vertical end strips, a minimum of one 4x18 inch strip shall be applied at least 

every 12 feet, as practicable. 

If retroreflective sheeting is applied in a horizontal pattern, at least one 4x36 inch strip, or two 

4x18 inch strips, one above or next to the other, shall be applied as close to each end of the car as 

practicable. Between these end strips, a minimum of one 4x18 inch strip shall be applied at least 

every 12 feet, as practicable. 

Note: these are the general specifications for freight cars. The specifications vary for tank cars, 

flat cars, cars of special construction and locomotives. 

What size of retroreflective sheeting is acceptable? 

§ 224.105 Sheeting dimensions and quantity. 

The amount of retroreflective sheeting to be applied to each car or locomotive subject to part 224 

is dependent on the length of the car or locomotive and the color of the sheeting. For purposes of 

this part, the length of a railroad freight car or locomotive is measured from endsill to endsill, 

exclusive of the coupler and draft gear. Table 2 of Subpart B to part 224 provides the minimum 

quantity requirement for retroreflective sheeting on freight rolling stock. 

What color(s) of retroreflective sheeting are acceptable and how will we be able to 

determine if the product is in compliance? 

224.103 Characteristics of retroreflective sheeting.

Retroreflective sheeting applied pursuant to part 224 shall be yellow, fluorescent yellow, or 

white as specified by the chromacticity coordinates of ASTM International’s Standard D 4956-

04.1

 

The characters “FRA-224”, constituting the manufacturer’s certification that the retroreflective 

sheeting conforms to the requirements of paragraphs (a) through (c) of § 224.103, shall appear at 

least once on the exposed surface of each piece of sheeting in the final application. The 

characters shall be a minimum of three (3) millimeters high, and shall be permanently stamped, 

etched, molded or printed within the product and each certification shall be spaced no more than 

four (4) inches apart. 

Are both vertical and horizontal applications in compliance? 

 

1

 The American Association of Railroads Field Manual Rule 66, 2006 Issue, specifies, “yellow only” for 

applications. 
Federal Railroad Administration 

14 - 4 

On railroad freight cars other than flat cars and tank cars, retroreflective sheeting shall be applied 

in either a vertical or horizontal pattern along the length of the car sides, with the bottom edge of 

the sheeting as close as practicable to 42 inches above the top of rail. Retroreflective sheeting 

shall not be applied below the side sill. 

How are the strips to be spaced? 

If retroreflective sheeting is applied in a vertical pattern, at least one 4x36 inch strip or two 4x18 

inch strips, one above the other, shall be applied as close to each end of the car as possible. 

Between these two vertical end strips, a minimum of one 4x18 inch strip shall be applied at least 

every 12 feet, as possible. 

If retroreflective sheeting is applied in a horizontal pattern, at least one 4x36 inch strip, or two 

4x18 inch strips, one above or next to the other, shall be applied as close to each end of the car as 

possible. Between these end strips, a minimum of one 4x18 inch strip shall be applied at least 

every 12 feet, as possible. 

Note: these are the general specifications for freight cars. The specifications vary for tank cars, 

flat cars, cars of special construction and locomotives. 

How do I submit a Compliance Report to the FRA? 

A Compliance Report may be submitted electronically or by filing a paper copy of completed 

Form FRA F6180.113 (found in Appendix B to 49 CFR Part 224) with the following: 

Creative Information Technology, Incorporated (CITI) 

4601 North Fairfax Drive, Suite 1100 

Arlington, VA 22203 

703-548-3313 Extension 223 

POC: Angelica Mamani 
15 - 1 

Chapter 15 

Guidelines for Enforcement of Mechanical Requirements for 

Rail Grinding Equipment 

Introduction

Subsequent to an incident in November 2006, that involved a rail grinder (rail grinding set), and 

corresponding investigations by the Federal Railroad Administration (FRA), there have been 

several inquiries about the proper application of regulatory and statutory requirements to the type 

of equipment involved in the incident. Rail grinding sets are unique and warrant different 

treatment than self propelled vehicles that are considered locomotives under Federal regulations. 

The two major U.S. operators of rail grinding trainsets are Loram and Harsco. Major railroads 

also operate their own rail grinding equipment. Typical configurations for rail grinding trainsets 

are noted on the next page as (1) locomotive powered grinding trains, and (2) self-powered rail 

grinding units. The following are guidelines for enforcing the various requirements that apply to 

the rail grinding sets: 

Guidelines for Enforcement of Mechanical Requirements: 

• 49 U.S.C. §20701 (Locomotive Inspection Act) - The power unit and the location of the 

control stand in the rail grinding sets each constitute a locomotive under the statute, but 

not the regulations. 

49 CFR Part 229 (Railroad Locomotive Safety Standards RLSS) does not apply to the rail 

grinders because the locomotives regulated under Part 229 do not include specialized 

maintenance equipment. The Locomotive Inspection Act permits FRA to write violations 

when a “locomotive or tender and its parts and appurtenances are [not] in proper 

condition and safe to operate.” To determine whether a power unit or the location of the 

control stand is safe to operate, FRA may use regulatory provisions including those 

contained in Part 229 as guidelines. FRA inspectors commonly make safety 

determinations based on observations of equipment and records, as well as industry and 

regulatory experience. After determining that a power unit or the location of the control 

stand is unsafe to operate, FRA should cite only the statute, and not the regulation when 

recommending a violation. 

 

Although Part 229 does not apply to rail grinding sets, the regulation should not be 

ignored when assessing the safety of the equipment. The safety rationale supporting 

regulatory requirements, particularly those contained in Part 229 Subpart C, may be 

relevant to the rail grinding sets, because the equipment is being used in a similar 

manner. FRA may frame a violation of the statute using facts that would commonly 

support a violation of the Federal regulations. For example, if FRA discovers a rail 

grinding set with a 3 inch flat spot on wheel R1 of the power unit, it would be proper for 

a violation report to state that “the power unit of the rail grinding set is not safe to operate 

as required by 49 U.S.C. §20701, because “Wheel R1 has a 3 inch flat spot. Running this 

rail grinding set with a flat spot of this size could lead to a derailment.” This is not a Part 
Motive Power and Equipment Compliance Manual 

15 - 2 

229 violation, but it is a defective condition that makes the power unit or the location of 

the control stand unsafe to operate. In this example, FRA is using the wheel requirement 

from 49 CFR § 229.75 to inform its safety assessment of the equipment and describe the 

violation. Other defective conditions under Part 229 may not make the power unit or the 

location of the control stand unsafe to operate. For example, it would be very difficult to 

argue that a defective step light makes the power unit or the location of the control stand 

unsafe to operate. Ultimately, the FRA inspector is responsible for explaining in the 

violation report why the defect makes the power unit or the location of the control stand 

unsafe to operate. 

• 49 U.S.C. §20302 (Safety Appliance Act) - The rail grinding sets are a train under the 

statute, but not the regulations. 

The power brake portions of the statute apply to the rail grinding sets, and the specific 

requirements in 49 CFR Part 232 are not applicable. Section 20302(a)(4) requires that a 

locomotive be equipped with a power-driving wheel brake and appliances for operating 

the train-brake system. 

50% equipped brake requirement: Section 20302(a)(5) requires that at 

least 50% of the vehicles in a train be equipped with power brakes and that 

all the vehicles on an associated train line that are equipped with power 

brakes shall have their brakes used and operated by the engineer. 

100% operative brake requirement: As all of the units in a rail grinding set 

are equipped with power brakes and are on an associated train line, the 

statute requires that 100% of the vehicles in the train have operative 

brakes unless they are being moved for repair under 49 U.S.C. §20303. 

 Brake inspections: Because the rail grinding sets are subject to Section 

20302(a)(5), FRA expects the railroads and operators of this equipment to have an 

inspection regimen in place that will ensure that the crews operating the 

equipment are aware of whether the brakes are in compliance with the applicable 

statutory requirements. 

 Other safety appliance requirements: Sections 20302(a)(1) and (a)(2) require 

that vehicles be equipped with efficient hand brakes, sill steps, and other safety 

appliances that ensure the safety of employees as they mount and dismount 

equipment. Except for those appliances addressed by 49 CFR Part 231 (see 

discussion below), FRA should cite only the statute for violations of this type. 

• 49 U.S.C. §20303 (Safety Appliance Act) - Section 20303 (which restricts the use and 

movement of vehicles with defective or inoperative safety appliances) only permits the 

movement of a vehicle with defective safety appliances to the nearest available place 

where the necessary repairs can be performed. 
Motive Power and Equipment Compliance Manual 

15 - 3 

If power brakes are discovered defective at a location where repairs are routinely made, 

repairs are required to be made before the vehicle departs that location. Similarly, if the 

brakes become defective enroute, the rail grinding set may be moved only for the purpose 

of repair to the nearest location where the necessary repairs can be made. Guidelines for 

determining locations where necessary repairs can be performed can be found at 49 CFR 

§ 232.15(f). FRA should cite only the statute for violations of this type. 

• 49 CFR Part 231 (Safety Appliance Regulation) - Due to their unique design and 

purpose, rail grinding sets are considered “cars of special construction” under 49 CFR 

§ 231.18. Therefore, they are required to have (as nearly as possible based on the design 

limitations of the vehicle) the same complement of handholds, sill steps, ladders, hand 

brakes, and running boards as required for a car of the nearest approximate type. As with 

any equipment covered by 49 CFR Part 231, any additional safety appliances on the 

equipment must comply with the requirements of 49 CFR Part 231. 

Guidelines for Enforcement of Roadway Maintenance Machine Requirements: 

49 CFR Part 214 (Railroad Workplace Safety) - The rail grinding sets must comply with 49 CFR 

§ 214, Subparts C and D. 

Subpart D: “On-Track Roadway Maintenance Machines and Hi-Rail Vehicles” contains various 

requirements regarding the safety equipment required to be on such machines as well as 

provisions related to their design and operation. Subpart C: “Roadway Worker Protection” 

includes training requirements that apply to operators of rail grinding sets. These requirements 

are intended to prevent accidents and casualties. For convenience, the attached chart 

"Application of 49 CFR Part 214, Subpart D," summarizes the most significant provisions of 49 

CFR Part 214, Subpart D that have been traditionally applied to on-track roadway maintenance 

machines (RMMS). It is not intended to be all-inclusive. It should be noted that additional or 

more stringent requirements in the CFR or in the railroad safety statutes may also apply. For 

example, when the rail grinding sets are moved over the road, 49 U.S.C. §§20302 and 20303 

apply. Recommendations of violations against a rail grinding set should be based on the same 

supporting facts and cite the same pertinent regulatory provisions as other equipment covered by 

49 CFR Part 214. 

Guidelines for Enforcement of Operating Practices Requirements: 

49 CFR Part 240 (Qualification and Certification of Locomotive Engineers) - The rail grinding 

sets constitute specialized roadway maintenance equipment. 

The rail grinding sets, like most specialized maintenance equipment, are unique in both its design 

and operation. Requiring a certified locomotive engineer (LE) to operate such equipment when 

it is moved from one work site to another would be operationally restrictive and potentially 

unsafe since in most instances, an LE certified under Part 240 will not be familiar with the 

specific operation of specialized maintenance equipment. Safety is better served by permitting 

an individual familiar with the specific piece of equipment to operate it from one work site to 

another with the aid of a pilot, where appropriate. Although Federal regulations do not 
Federal Railroad Administration 

15 - 4 

specifically address the territorial qualifications of either the operator or any pilot that may be 

used when operating specialized maintenance equipment, FRA believes that safe railroading 

dictates that such individuals should be qualified and familiar with the territory over which the 

equipment will be operated. FRA strongly recommends and encourages the use of individuals 

that are qualified on the territory over which the equipment will be operated when such 

equipment is traveling to and from a work site. 

Application of 49 CFR Part 214, Subpart D 

(Note: There may be additional or more stringent requirements applicable to this equipment, its 

owner, and its operator in this or other subparts or parts of the CFR or in the railroad safety 

statutes, particularly, 49 CFR Part 232 and 49 U.S.C. Sections §§20302 and 20303. This chart is 

not intended to be all-inclusive and is provided as a helpful summary of the requirements in 

Subpart D of Part 214 and should be used in conjunction with the regulatory text to determine 

compliance with this subpart). 

Requirement On-track RMM’s - non-highway and light weight greater than 7,500 

lbs. and not used exclusively for inspection of track 

Pre 1/1/91 Existing – 

Post 1/1/91 

New - ordered after 

12/26/03 and 

completed after 

9/27/04 

Beacon (360-degree 

warning light) 

Not Required* Not Required* 509 (c) (RMM 

without fixed roof and 

less than 17,500 lbs. 

exempt) 

Brake light (or 

reflective material, or 

reflective device) 

Not Required* 

 

517 (d) - retrofit - 

brake light or 

reflective material, 

or reflective device 

509 (d) - brake light 

Braking system Not Required* but see 

529 

Not Required* but 

see 529 

507 (a)(5) 

Change-of-direction 

alarm 

Not Required* 

 

517 (a) - retrofit 

 *If adds safety 

value 

511 (b) 

Daily inspection 

 

527 (a) 527 (a) 527 (a) 

Fire extinguisher Not Required* Not Required* 507 (a)(7) 

First aid kit Not Required* Not Required* 507 (a)(6) 

Flagging equipment 

 

 

521 (lone, or lead and 

trailing piece in 

roadway group if RR 

rules require flagging 

equipment) 

521 (lone, or lead 

and trailing piece in 

roadway group if 

RR rules require 

flagging equipment) 

521 (lone, or lead and 

trailing piece in 

roadway group if RR 

rules require flagging 

equipment) 
Motive Power and Equipment Compliance Manual 

15 - 5 

Requirement On-track RMM’s - non-highway and light weight greater than 7,500 

lbs. and not used exclusively for inspection of track 

Pre 1/1/91 Existing – 

Post 1/1/91 

New - ordered after 

12/26/03 and 

completed after 

9/27/04 

Headlight 513 (c) 513 (c) 509 (a) 

Heating and ventilation Not Required* 517 (b) - retrofit 

(required if operated 

at temp. less than 50 

deg. and equipped 

or has been 

equipped) 

505 (g) for RMMS 

other than 505 (a)(1)-

(5), regulators, etc. 

with enclosed cabs 

Horn 513 (b) permanent or 

portable 

513 (b) permanent 

or portable 

511 (a) permanent 

Light weight display Not Required* 517 (c) - retrofit 507 (d) 

Operator seat (or 

position, if standing) 

527 (c)(5) 527 (c)(5) 507 (a)(1) except as 

required under 507(b); 

operator standing 

Record of defective 

conditions 

533 (d) 533 (d) 533 (d) 

Rearward viewing 

devices 

Not Required* Not Required* 509 (e) 

Safe and secure 

position - handholds, 

handrails, or a secure 

seat for workers 

transported on 

machine; protection 

from moving parts 

513 (a) - retrofit 513 (a) - retrofit 507 (a)(2) 

Safe and secure 

position for riders - 

identification by 

stenciling or other 

written notice (if used) 

518 518 518 

Safety glass & wipers Not Required* 517 (e) - 

retrofit/replace 

507 (a)(4) 

Secure footing for 

floors, decks, stairs, 

and ladders 

519 519 519 

Speed indicator Not Required* Not Required* 507 (c) - more than 

32,500 lbs and speed 

greater than 20 mph 

Tag defective item(s) 527 (b) 527 (b) 527 (b) 
Federal Railroad Administration 

15 - 6 

Requirement On-track RMM’s - non-highway and light weight greater than 7,500 

lbs. and not used exclusively for inspection of track 

Pre 1/1/91 Existing – 

Post 1/1/91 

New - ordered after 

12/26/03 and 

completed after 

9/27/04 

Towing 525 525 525 

Work lights Not Required* Not Required* 509 (b) 

* NOTE on “not required”: If an existing on-track RMM is equipped with a device only 

required on new equipment, the device should be in proper working condition. If inspectors 

encounter a broken or inoperable “not required” device, they should write a comment to the 

railroad describing the defective condition and indicate that a machine with “a condition that 

inhibits its safe operation” is subject to a good faith challenge, especially where roadway 

workers working on or near the machine may be relying in part on such a device to alert 

them to a machine’s presence or proximity. FRA expects that any such inoperable device 

shall be discussed in the job briefing. 

 
16 - 1 

Chapter 16 

Wayside Detector/Train Inspection Guidance 

AAR and Class I Railroad Initiatives

To reduce or mitigate the adverse effects of heavy axle loads on track infrastructure, 

degradation of freight car components and as tools for enhanced train inspections, the 

railroads have started leveraging the emerging wayside detection technology. Besides 

addressing the higher or distressed-and-unsafe “stress state” of equipment and track, the 

railroads intend to achieve, at a minimum, an equivalent or enhanced level of railroad 

safety by using the wayside detection technology. To achieve this goal, the Advanced 

Technology Safety Initiative (ATSI) was implemented on October 1, 2004 by the 

Association of American Railroad’s (AAR’s) Technical Services Working Committee. 

ATSI is a predictive and proactive maintenance system that uses the best available 

technology to detect and report potential safety problems and poorly performing 

equipment before they result in accidents or undue rail damage. 

The overall objectives of the railroads are to enhance the quality, efficiency and safety of 

the train inspection processes through this technology including any assessment of the 

underlying causal issues. It is believed that a mature wayside detector system can provide 

remote intervention capabilities by combining facets of this technology that relate to the 

prevention of incidents, detection of incidents, notification of incidents and recovery 

from incidents. 

Under the auspices of the AAR, the Class I railroads and private car owners have already 

embarked upon technology driven train inspections. There are a variety of wayside 

detectors (over 130) already deployed throughout the U.S. and the deployment list is 

rapidly growing. The initial objective of this undertaking was to reduce the “stress state” 

of the railroads, that is, to fix or remove from revenue service problematic equipment 

(poorly performing and defective equipment) before it severely damaged the track 

infrastructure. That is, the “predictive and proactive maintenance system” of in-service 

equipment is to identify the component’s deteriorating performance through different 

levels of degradation to the final level, at which time operations must be interrupted to 

mitigate the condition. The concept consists of successive “triggers” to indicate 

progressive degradation and preventive action(s) to be taken. 

The wayside detector technologies consist of three general categories: wayside 

performance detection, machine vision and wayside condition detection. Under the ATSI 

initiative all of these technologies will eventually feed the Transportation Technology 

Center Incorporated’s (TTCI’s) Integrated Railway Remote Information Service 

(InteRRIS®) system, which will then feed the “sorted” data into the Equipment Health 

Monitoring System (EHMS) at the Railinc. Railinc, which is AAR’s IT provider 

headquartered at Cary, North Carolina, then generates equipment alerts to the car owners 

through the EHMS. 
Federal Railroad Administration 

16 - 2 

Table 1: Detector Locations by Railroad, City and State 

Type Railroad City State 

TPD FAST-TTC Pueblo CO 

TPD BNSF Argyle IA 

TPD BNSF-Track 1 Argyle IA 

TPD BNSF-Track 2 Argyle IA 

TPD BNSF Victorville CA 

TPD BNSF Chriesman TX 

TPD BNSF Sandpoint ID 

TPD BNSF Joppa MT 

TPD BNSF-Track 1 Ludlow CA 

TPD BNSF-Track 2 Ludlow CA 

TPD BNSF Trinidad CO 

TPD BNSF Flagstaff AZ 

TPD BNSF Nonpareil NB 

TPD BNSF Pomona MO 

TPD BNSF Maupin OR 

TPD BNSF St. Croix WI 

TPD CSXT Carfax VA 

TPD FEX La Piedad MX 

TPD FXE Nazareno MX 

TPD NS Eggleston VA 

TPD NS-Track 1 Science Hill KY 

TPD NS-Track 2 Science Hill KY 

TPD UP Evanston WY 

TADS BNSF Antioch NE 

TADS BNSF Kingman AZ 

TADS BNSF Velox WA 

TADS CP Arnold BC 

TADS CSXT Hague GA 

TADS NS Flat Rock KY 

TADS UP Martin Bay NE 

WILD AMTK-Track 2 Edgewood MD 

WILD AMTK-Track 3 Edgewood MD 

WILD AMTK-Track 1 Mansfield MA 

WILD AMTK-Track 2 Mansfield MA 

WILD BNSF-Track 1 Atherton MO 

WILD BNSF-Track 2 Atherton MO 

WILD BNSF-Track 1 Bagdad CA 

WILD BNSF-Track 2 Bagdad CA 

WILD BNSF-Track 1 Bingham NE 

WILD BNSF-Track 1 Bismarck ND 

WILD BNSF-Track 1 Cochrane WI 

Type Railroad City State 

WILD BNSF-Track 2 Cochrane WI 

WILD BNSF-Track 1 Kirkland TX 

WILD BNSF-Track 1 Mesa WA 

WILD BNSF-Track 1 Peshastin WA 

WILD BNSF-Track 1 Denver CO 

WILD BNSF-Track 1 Seymour MO 

WILD BNSF-Track 1 Wheatland WY 

WILD BNSF-Track 1 Winton CA 

WILD CN-Track 1 Aldershot ON 

WILD CN-Track 2 Aldershot ON 

WILD CN-Track 3 Aldershot ON 

WILD CN-Track 1 Moncton NB 

WILD CN-Track 1 Winnipeg MB 

WILD CN-Track 1 Arnold BC 

WILD CN-Track 1 SainteHelene de 

Bagot 

QC 

WILD CN-Track 1 Bentonia MS 

WILD CN-Track 1 Winnipeg MB 

WILD CN-Track 2 Winnipeg MB 

WILD CN-Track 1 Cedars QC 

WILD CN-Track 2 Cedars QC 

WILD CN-Track 1 Dugald MB 

WILD CN-Track 1 Dubuque IA 

WILD CN-Track 1 Neenah WI 

WILD CN-Track 1 Melville SK 

WILD CN-Track 1 Jasper AB 

WILD CN-Track 1 Vinsulla BC 

WILD CN-Track 1 Hornepayne ON 

WILD CN-Track 1 Sioux 

Lookout 

ON 

WILD CN-Track 1 Prince 

George 

BC 

WILD CN-Track 1 Nattress MB 

WILD CN-Track 1 Nechako BC 

WILD CN-Track 1 Williams 

Lake 

BC 

WILD CN-Track 1 Edmonton AB 

WILD CN-Track 1 Waukesha WI 

WILD CN-Track 1 Grand Mere QC 
Motive Power and Equipment Compliance Manual 

16 - 3 

WILD CN-Track 1 Stony Plain AB 

Type Railroad City State 

WILD CN-Track 1 Capreol ON 

WILD CN-Track 1 Uncas AB 

WILD CN-Track 1 Zephyr ON 

WILD CN-Track 1 Vinsulla BC 

WILD CN-Track 1 Winnipeg MB 

WILD CN-Track 1 Battle Creek MI 

WILD CN-Track 1 Champaign IL 

WILD CP-Track 1 Calgary AB 

WILD CP-Track 1 Toronto ON 

WILD CP-Track 1 Calgary AB 

WILD CP-Track 2 Calgary AB 

WILD CP-Track 1 Minneapolis MN 

WILD CP-Track 1 Golden BC 

WILD CP-Track 1 Moose Jaw SK 

WILD CP-Track 1 Toronto ON 

WILD CP-Track 1 Moose Jaw SK 

WILD CP-Track 1 Winnipeg MB 

WILD CP-Track 1 St. Paul MN 

WILD CP-Track 1 Montreal QC 

WILD CP-Track 1 Sudbury ON 

WILD CP-Track 1 Thunder 

Bay 

ON 

WILD CSX-Track 1 Cartersville GA 

WILD CSX-Track 1 Grafton OH 

WILD CSX-Track 2 Grafton OH 

WILD CSX-Track 1 Johnson 

City 

TN 

WILD CSX-Track 1 Lowell WV 

WILD CSX-Track 1 Middlesex NJ 

WILD CSX-Track 1 Pendleton IN 

WILD CSX-Track 2 Pendleton IN 

WILD CSX-Track 1 Springfield PA 

WILD CSX-Track 2 Springfield PA 

Type Railroad City State 

WILD CSX-Track 1 Walthourvil

le 

GA 

WILD CSX-Track 1 Self Creek AL 

WILD FEC-Track 1 Miami FL 

WILD FXE-Track 1 Corralejo GT 

WILD FXE-Track 1 Sauz CH 

WILD NS-Track 1 Knoxville TN 

WILD NS-Track 1 Marietta PA 

WILD NS-Track 2 Marietta PA 

WILD NS-Track 1 Altoona PA 

WILD NS-Track 2 Altoona PA 

WILD NS-Track 1 State Line IA 

WILD NS-Track 1 South Bend IN 

WILD NS-Track 2 South Bend IN 

WILD NS-Track 1 Waverly VA 

WILD NS-Track 2 Waverly VA 

WILD UP-Track 1 Chamberlin TX 

WILD UP-Track 1 Donaldson AR 

WILD UP-Track 1 Elton LA 

WILD UP-Track 1 Fields OR 

WILD UP-Track 1 Gothenburg NE 

WILD UP-Track 2 Gothenburg NE 

WILD UP-Track 1 Martin Bay NE 

WILD UP-Track 1 Millican TX 

WILD UP-Track 1 East Peru WY 

WILD UP-Track 2 Red Desert WY 

WILD UP-Track 1 Stuttgart AZ 

WILD UP-Track 1 Sunset CA 

WILD UP-Track 1 Westvaco WY 

WILD UP-Track 1 Wister CA 

InteRRIS® is a data warehouse, accessible through the Internet. It is designed to 

assemble and integrate data from all types of devices that monitor vehicle performance 

and return 

added value to its users by giving quantitative evaluations of rail vehicle performance by 

enabling planned maintenance and monitoring post maintenance performance to provide 

quality control checks on the maintenance performed. Railinc located in Cary, North 

Carolina is the industry’s largest and most accurate source for real-time interline rail 

data. Railinc maintains Industry Reference Files (IRFs) and Umler data. Umler is the 
Federal Railroad Administration 

16 - 4 

electronic resource that contains critical data for North American transportation 

equipment depicting list of all nationwide fleet by car initials and numbers and specific 

car data. Railroads, equipment owners, agents, shippers, ports, suppliers, industry 

consultants, government agencies and car maintenance facilities are all users of Umler. 

The first effort under this new initiative is the use of data from Wheel Impact Load 

Detectors (WILD) to monitor the health of in-service railcar wheels. When a freight car 

wheel exerts a peak impact load of 90 kips or above as measured by a WILD site, it is not 

operating effectively, is considered “out of round” and on the path to failure. The 

program provides a window of opportunity that opens when a wheel reaches a peak 

impact load of 65 kips. The very first WILD detectors started appearing at Conrail in the 

early 1990’s to protect against flat wheel impacts on concrete ties. It appears that WILD 

technology has been quite useful in indicating progressive component degradation using 

successive wheel impact load thresholds as “alert” levels (see WILD description later). 

Future Considerations for Wayside Detectors

FRA encourages the use of new technology when appropriate. FRA’s mission is to 

promote railroad safety. To carry out this mission, FRA enforces Federal safety 

standards. The safety standards are tailored to the technology that exists at the time that 

they are promulgated. Often, new technology can be used in conjunction with existing 

technology to enhance safety. Railroads are also increasingly using wayside detection 

technology and their embedded event recorders to assess the cause(s) of train accidents 

and derailments. This information can also be helpful to FRA during an accident or 

derailment investigation. The following is a list of common wayside detector features: 

 Data-driven tools for railways, vehicle owners, vehicle builders, vehicle maintenance, 

and component manufacturers, 

 Products that monitor performance from wayside, 

 Capabilities for the user to make predictive, condition-based rather than reactive 

vehicle maintenance decisions, 

 Automation of communication processes, 

 Car owner access to equipment to intervene and effect predictive maintenance 

strategy, 

 Improved maintenance planning and scheduling for proactive management of 

component life cycle and optimized/ scheduled vehicle repair, 

 Automated maintenance inspection for improved reliability of measurements, reduced 

need for manual inspection, and finding defective car/ truck components, 

 Improved safety, 

 Improved utilization of car fleet, 

 Reduced damage to track and lading, 

 Capability to cross reference data and produce more efficient gains, 

 Supplements current inspections and adds to network efficiency, 

 Networking and management of detector data from all railroads, 

 Continuous updates of inspection record of each car for critical running gear 

performance, 
Motive Power and Equipment Compliance Manual 

16 - 5 

 Interchange data with other railroads/ car owners in advance of car interchange, 

 Enhancement of line-points with automated in-coming lineup of workload by 

defining predictive workload, providing easily viewed and printed workload for incoming trains/ cars, speeding up normal visual inspections by targeting only problem 

cars, and extending interval between conventional visual inspections, 

 Enhancement of railroad and car-owner “mechanical desk” knowledge of car “health 

warnings” by using continuous and automated electronic form to spell out symptoms 

for preventive action, directing maintenance to least disruptive time in the car cycle, 

using trend analysis to optimize maintenance cycle, and instructing special attention 

and handling for problem cars, and 

 Verification, accountability and ability to audit. 

Waiver(s) Issued

Notably, the Union Pacific Railroad (UP) recently applied and was granted relief from single car 

air brake tests (SCABTs) on empty cars utilizing defect information on irregular wheels and 

defective bearings gathered by wayside detectors such as WILD, ABD, HBD, HWD, WPM, 

WPD or TAD. This relief involves empty cars at UP’s North Platte, NE, facility wherein 

replacement of “non-FRA-condemnable” wheel sets with minor defects that are condemnable 

under AAR standards is ongoing per UP’s in-train wheel set replacement program as a 

preventive maintenance tool. A copy of the Safety Board approval letter, dated January 16, 2009, 

granting this waiver of compliance from Title 49 CFR § 232.305(b)(2) is located in Appendix B. 

 For further details on this waiver, see FRA Docket Number FRA-2007-28454. 

Wayside Detector Glossary of Terms

To better understand the nomenclature and “language” of wayside detectors currently used 

throughout the U.S. a glossary of terms has been provided below: 

 ABD: Acoustic Bearing Detector. Measures acoustic signatures, indicates bearing 

defects, and signifies derailment prevention. 

 AISC: Automated Inspection of System Components. 

 AOA: Angle of attack of a wheel set is defined as the angle between the track radial 

line and the center line of the wheel set’s axle. It is a measure of the lateral 

creepage and lateral loads exerted on the track. It indicates the dynamic behavior and 

curving performance of the bogie. High value indicates a vehicle with defects and 

potential for wheel climb derailment. 

 ASAIS: Automated Safety Appliance Inspection System. Measures dimensions, 

detects missing appliances and compares standards; and signifies set-out 

performance. 

 BOJ: Burnt-off Journal results when a roller bearing overheats and seizes. This 

condition generally results in missing a portion of the affected axle. The axle journal 

along with the associated bearing may be discolored and completely separated from 

the rest of its wheel set. 

 Broken Rail Detection: Acoustic method or fiber optics or strain gages or track 

circuit. Signifies derailment prevention from broken rail. 
Federal Railroad Administration 

16 - 6 

 BSM: Brake Shoe Module. Measures thickness and missing parts using video 

machine vision, indicates brake shoe defects, and signifies damage prevention. 

 CAD: Cracked Axle Detector. Uses laser to generate surface waves along the length 

of the axle, measures amplitudes of generated waves by air coupled ultrasonic 

transducers, detects cracks as reflected waves by signature cracks; signifies 

derailment prevention. 

 CWD: Cracked Wheel Detector. Uses laser-Air Hybrid Ultrasonic Technique 

(LAHUT) to create surface and body waves in the wheel which are then recorded 

using air-coupled ultrasonic transducers. Modification of waves by reflection and 

refraction at the crack is then detected as a combination of peaks in the frequency 

domain; signifies derailment prevention. 

 DED: Dragging Equipment Detector. Signifies damage and derailment prevention. 

 HBD: Hot Box Detector. Measures temperature change, indicates roller bearing 

defects, and signifies derailment prevention. 

 HWD: Hot/Cold Wheel Detectors. Measures wheel temperature, indicates airbrake 

system defects, and signifies brake performance. 

 IAM: Inter-axle misalignment is the internal misalignment between the two wheel 

sets in a bogie, and is measured as the AOA of the leading wheel set minus the 

AOA of the trailing wheel set. IAM measures the dynamic performance such that a 

higher value indicates a vehicle with defects. 

 LAD: Low Air-hose Detector. Measures air-hose height above rail using video 

machine vision, indicates coupler/air-hose defects, and signifies train stop 

performance. 

 OILD: Overload/Imbalance Load Detector. Measures wheel load imbalance using 

WILD weigh-in-motion, indicates shifted loads, and signifies curving performance 

and derailment prevention. 

 Rail Flaw Detection: Laser based ultrasonic NDT. Signifies damage prevention of 

rails with flaws. 

 TAD: Trackside Acoustic Detector. Measures acoustic signatures, indicates roller 

bearing defects, and signifies derailment prevention. 

 TBOGI: Truck/Bogie Optical Geometry Inspection. Measures geometric faults in 

 the alignment and tracking of bogie wheel sets using laser/optical means, indicates 

bogie performance deficiencies, and indicates set-out performance. 

 TE: Tracking error is the lateral distance between the center lines of the axles in the 

bogie and is defined as the tracking position of the leading wheel set minus the 

tracking position of the trailing wheel set. A higher value of the TE also represents a 

degraded dynamic performance of the vehicle. 

 THD: Truck Hunting Detector. Measures lateral instability in terms of poor lateral 

dynamic performance, indicates truck and suspension defects, and signifies 

derailment prevention. 

 TP: Tracking is defined as the center line of the wheel set compared to the track 

center line. This is an interim parameter which is used to define the Tracking Error 

(TE) of a bogie. 

 TPD: Truck Performance Detector. Measures lateral/vertical wheel loads and angle 

of attack (AOA), indicates truck and suspension defects based on curving 
Motive Power and Equipment Compliance Manual 

16 - 7 

performance, and signifies derailment prevention. 

 TS: Thermal Scan. Using thermal sensors detects heat generated at the interface 

between the brake shoe and the wheel to determine brake application, is a 

complement to BSM to assess brake shoe condition, and signifies damage prevention. 

 WBT: Warm Bearing Trending. Measures bearing temperature between detectors 

and identifies excessive trends. 

 WILD: Wheel Impact Load Detector. Measures impact loads, indicates wheel tread 

defects, and signifies damage prevention. 

 WPM or WPD: Wheel Profile Module or Wheel Profile Detector. Measures wheel 

profile dimensions using laser/video scanners, indicates wheel rim/tread shape 

defects, and signifies set-out performance. 

 WTT: Wheel Temperature Trending. 

Wayside Detector Treatise

There are three aspects of wayside monitoring of a railway vehicle: 1) its present condition and 

required maintenance, 2) detection and diagnosis of developing faults, and 3) trending for future 

performance for preemptive, preventive and proactive maintenance strategies. In this context, the 

wayside detectors are of two types, reactive systems and predictive systems. Reactive 

systems detect actual faults on the vehicles. Generally the information from reactive systems is 

not suited for trending, but is of importance to protect the equipment from further damage due to 

the fault. Some examples of reactive detector technology are the DED, HBD and HWD. 

Predictive systems, on the other hand, are capable of measuring, recording and trending the ride 

performance of the vehicles and also specific components. From the collected information it is 

possible to analyze the condition of the equipment to predict possible failures and faults that may 

occur in a near or distant future. This makes it easier to plan the maintenance activity ahead and 

also to utilize the equipment in a more efficient way. Some examples of predictive detector 

technology are the ABD, TPD, T/BOGI, THD, TAD, WILD, WPM, WPD, AISC, ASAIS, and 

BSM. 

 Wheel Impact Load Detector (WILD)

WILD is an electronic data collection device that measures vertical wheel forces (impacts 

from damaged wheels as shown in Figure 1) on the rail via rail mounted strain gages. It 

consists of a system of strain gauges placed on the web of the rail, as shown in Figures 2

and 3, to measure rail deformation under traffic. It measures impact forces caused by flat, 

shelled, spalled, out-of-round, built-up-tread and damaged wheels. The high impact 

forces damage vehicles, cargo, and infrastructure. Preemptive reduction of high impact 

forces by truing faulty wheels and removing damaged wheels entails benefits due to 

reduction in derailments, rail fatigue, bearing damage, cold weather rail fractures, car and 

truck damage, concrete tie cracking and wood tie plate cutting; and increment in wheel 

tread life and fuel efficiency. 
Federal Railroad Administration 

16 - 8 

The various features of WILD detectors, Figure 4, may include: impact force monitoring, 

train-vehicle-wheel information, bi-directional traffic, automatic car counting and 

identification (with valid car library), self-diagnostics, instrumentation layout 

optimization for fleet wheel diameters, and AAR Rule 41 Standard compliance. The 

corresponding measurements may include: car IDs, wheel IDs, nominal, peak and 

dynamic wheel loads, axle loads, train speed and length, tonnage (by train, week and 

month). 

Figure 3: A Typical Layout of WILD Measurement Site

Figure 1: A Damaged Wheel 

Figure 2: A Typical Strain Gage Installation on

Rail Web over a Crib 
Motive Power and Equipment Compliance Manual 

16 - 9 

The data collected by the WILD detector network in the U.S., Canada and Mexico resides 

in the Equipment Health Management System (EHMS), which is the AAR approved 

reference file maintained by Railinc (www.railinc.com). The various thresholds, per 

AAR’s Field Manual, indicating progressive component degradation are as follows: 

 

1) WILD-reading of 65 kips to less than 80 kips for a single wheel indicating an 

appropriate maintenance/ repair attention, termed as the “Window of Opportunity” 

alert level requiring issuance of first Maintenance Advisory from EHMS; 

 

2) WILD-reading of 80 kips to less than 90 kips for a single wheel indicating a 

warranted maintenance/ repair attention, termed as the “Opportunistic Repair” alert 

level requiring issuance of second Maintenance Advisory from EHMS; 

 

3) WILD-reading of 90 kips to less than 140 kips for a single wheel indicating an urgent

maintenance/ repair attention, termed as the “AAR Condemnable” alert level 

requiring issuance of third Maintenance Advisory from EHMS; and 

 

4) WILD-reading of 140 kips or greater for a single wheel indicating required

maintenance/ repair, termed as the “Final Alert” level resulting in the issuance of 

fourth Maintenance Advisory from EHMS. 
Federal Railroad Administration 

16 - 10 

 Truck Performance Detector (TPD)

TPD detectors monitor the response of car’s suspension system along curved track to 

signal worn or defective component conditions. Conditions detected by TPD are truck

warp, poor steering, hollow worn wheels and poor wheel load equalization. Detection of 

these ailments adds to the security against derailments. TPDs measure wheel/rail forces 

(vertical and lateral) via strain gauge sensors on the rails in selected reverse curves, 

Figure 5. They also measure the angle of attack (AoA – the angle taken by the axle 

relative to the direction of motion) of each axle with respect to the rail, which in 

combination with measured vertical and lateral forces provides information regarding the 

steering capability of the truck through curves. TPDs identify suspension systems that do 

not perform optimally in (or after negotiating) curves. Poor performance may result in 

derailments due to wheel climb, gauge spreading, rail rollover or track panel shift. Poor 

performance also contributes to wear on rail, special track work, wheel profiles and 

flanges. By identifying poor performers through performance-based monitoring, 

preventive maintenance can be performed, reducing derailment risks and 

 

Figure 4: A Typical WILD Deployment on Revenue Track indicating Instrumented Rail over 

Cribs 
Motive Power and Equipment Compliance Manual 

16 - 11 

improving the overall safety of rail operations. 

A typical TPD site may consist of an “S” curve arrangement where two curves (typically 

4 to 6 degrees) are in the opposite direction relative to each other (i.e., a right-hand and a 

left-hand curve with a tangent section separating them) as shown in Figure 6. This gives 

the possibility to collect data on the vehicles behavior in both right and left curves as well 

as in the tangent track. 

 Trackside Acoustic Detector (TAD) 

Vertical 

Load (V)

Lateral 

Load (L)

 Flange Climb → High L/V and AoA; Gage Spreading → High L 

 Warped Truck → High AoA; Wheel Unloading → Low V 

 Track Panel Shift → High NAL (Net Axle Load); Track Damage → High V 

 Rail Roll Over → High TSLV (Truck Side L/V) 

Figure 5: A Typical TPD Deployment on Revenue “S-Curve” Track Showing Vertical 

and Lateral Load (Collected) Data, and Indicating the Outcome of Their High 

Magnitudes 

Figure 6: A Schematic Showing the “S-Curved” Track and Location of Instrumented Cribs
Federal Railroad Administration 

16 - 12 

TAD wayside detectors monitor bearings by automatically detecting flaws in wheel 

bearings by evaluating the acoustic signature of the noise (1 kHz and above) created by 

the flaw, Figures 7 and 8, before the bearing becomes hot or seizes in service and results 

in accidents due to burned-off roller bearings. The most problems in roller bearings occur 

due to flaws such as cup spalls; cone spalls; spalled, etched, seamed rollers; water etched

raceways; and spun or loose cones. Arrested center plate rotation, defective side bearings, 

and hollow tread wheels add to the roller bearing woes. TADs can detect symptoms of 

bearing failure at a much earlier stage than hot box detectors (HBDs), and can spot flaws 

that a visual inspection may not detect. The TAD detectors may find internal roller 

bearing defects, long before a hotbox detector will detect the problem and so avoid 

possible derailments with the inevitable consequences of cost, safety, disruption to the 

network. 

TAD wayside detectors use an optimized array of microphones located on each side of 

the track, Figure 9. The microphones are spaced vertically and horizontally. The 

microphones simultaneously record signals and sensors identify each wheel of the 

passing train. The acoustic signals are analyzed over a wide range of frequencies. Since 

roller bearing flaws create noise – they produce an acoustic signature. The data is 

analyzed to ascertain the presence or absence of these signatures. Trains pass the TAD 

detector sites at 30 to 50mph. 

These detectors are used to mitigate failures, determine high risk bearings and identify 

severest defects using growler software. AAR has developed Rule 36A.3.c Cause for 

Removal (AAR Field Manual) for industry. This detection pertains to reducing burn-off 

derailments. It can be used for customized alarming for the high risk bearings and 

correlating hot bearings setouts with acoustic alarms. 
Motive Power and Equipment Compliance Manual 

16 - 13 

Figure 9: A Typical TAD Site in Revenue Service consisting of Microphone Array, 

Wheel Sensors and AEI 

Figure 7: Damaged Cups and Cones of 

Bearings 

Inner Ring or Cone Defect 

Roller Defect 

Outer Ring or Cup Defect 

Figure 8: Sound Signatures of 

Defects 
Federal Railroad Administration 

16 - 14 

 Low Air-Hose Detector (LAD)

Rail car braking systems depend upon the operational integrity of the coupling hoses that 

connect air pipes. By design, if a coupling hose fails or becomes otherwise uncoupled, a 

moving train is put into an emergency braking condition. Unintentional de-coupling can 

and does occur due to low-lying hoses, Figure 10, hitting obstructions in the roadbed. At 

a minimum, the resulting emergency stop causes delays, but may also damage wheels by 

creating flat spots and damage lading. The current solutions to this problem incorporate a 

non-contact, optical sensing approach. 

Using infrared light curtains (sensors) to visually inspect each air hose, the Low Air-Hose 

Detector measures the distance between the top of rail and bottom of each hose, Figure 

11. 

 

This examination is performed only in the appropriate area between vehicles to minimize 

the possibility of false alarms. It then identifies the leading and trailing tags nearest each 

hose that lies below user defined thresholds. The Low Air-Hose Detector integrates AEI 

tag readers to provide a complete record of offending vehicles, so corrective action can 

be taken at the most convenient location. 

 Truck Hunting Detector (THD)

Hunting trucks underneath rail cars can violently oscillate, Figure 12, from one rail to the 

other as they traverse along tangent track, inducing excessive lateral forces that 

significantly contribute to the rapid wear of rail and rail cars in a relatively short time. In 

the worst case, such hunting may lead to vertical wheel unloading and wheel climb 

derailment. Also, this particular type of degraded vehicle performance is a leading cause 

of damage to delicate lading. At a minimum, hunting trucks cause increased fuel 

consumption. Unchecked, severe damage to truck components and derailment can result. 

Figure 10: Air Hose State in a Train Figure 11: A Typical Low Air-Hose 
Motive Power and Equipment Compliance Manual 

16 - 15 

 

By measuring the lateral instability that indicates truck and suspension defects, THD 

wayside detectors, Figure 13, can be used to identify inspection and maintenance 

procedures for bad acting cars to reduce derailments due to flange climb. The hunting 

data collected by TTCI was used to confirm both the hunting conditions and the 

condemnable defects. The representative cars at various levels of hunting performance 

were sent to TTCI for inspection, test, teardown and repair. The teardowns showed that 

the suspect cars had worn truck components, couplers & coupler carrier plates and door 

mechanisms. Also, these cars showed signs of either (or both) 1) low truck warp restraint 

(high/worn wedges/ column wear liners) and 2) low truck/ car body rotational 

constraint (no constant contact sides bearings (CCSBs), no CCSB preload, melted or 

damaged CCSBs.) This data consisting of approximately 300 cars/year with a hunting 

index (HI) > or = 0.65 and approximately 450 cars/year with a hunting index (HI) > or = 

0.50 in a 12-month period confirmed that a car with either of the above noted hunting 

indices was condemnable at any time. As such, the car hunting condemnable indices (two 

HI readings above 0.50 in a twelve month period or a single HI reading above 0.65) were 

then implemented as new AAR interchange rule on July 1, 2006, and were adopted in the 

AAR Field Manual Rule 46. 

Figure 12: Lateral Displacements of an Axle in Hunting Truck 
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Similar in design to the wayside Wheel Impact Load Detector (WILD), THD wayside 

detectors can reside at the WILD detector locations. This add-on capability provides 

measurements of both the array of lateral forces, by the THD, exerted by a hunting truck 

on a passing train and the simultaneous readings of vertical forces from the WILD. As 

such the dynamic relationship between vertical and lateral forces is fully accounted to 

identify those critical instances where the wheel flange and rail gage face geometry may 

promote flange-climb derailments. These measurements are transformed into the 

“hunting index” to identify excessive side-to-side motion of bad acting cars. 

Some empty or lightly loaded cars are susceptible to truck hunting when operated at 

speeds over approximately 50 mph. In order to reduce the severity of truck hunting, 

trucks can be equipped with features such as constant contact side bearings, center plate 

extension pads, hydraulic snubbers or frame bracing. The restoration of worn truck 

components also mitigates truck hunting. 

 Hot Box Detector (HBD)

The function of hot box detectors is to detect overheated journals. Overheated roller 

Figure 13: Typical THD Deployment on Revenue Track Indicating Instrumented Cribs
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16 - 17 

bearings occur when inadequate lubrication or mechanical flaws result in an increase in 

bearing friction. This phenomenon is called a "hot box" in railway jargon. The bearing 

temperature can continue to rise and lead to complete failure of the axle, commonly 

referred to as a "burnt-off journal" (BOJ). A BOJ normally results in the derailment of 

the car on which it occurs. Should axle failure happen while the train is proceeding at a 

high speed, the derailment frequently results in multiple cars derailed and/or damaged. A 

hot box condition on roller bearing-equipped rail cars can elevate quickly and 

 become a BOJ within a few miles. 

The HBD senses radiant infrared heat energy emitted from the bearing as it passes over 

the detector scanner, Figures 14 and 15. The heat energy is converted to an electrical 

output proportional to the amount of heat and relative to the ambient temperature. 

Ambient temperature is determined by scanning the bottoms of the rail cars as they pass. 

Data is then processed to “warm” and “hot” levels. If the amount of energy sensed by the 

HBD exceeds preset values, then the appropriate action is warranted. 

 

The HBDs are rated to work in ambient temperatures. Severe environmental conditions, 

such as snow storms and blowing snow conditions, heavy rain and ice, can affect the 

quality of the scan data. The type of housing used for the roller bearings within the truck 

assembly can have an impact on the ability of the scanners to sense infrared heat energy. 

Figure 14: Typical Location for Scanning a Bearing 
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 Dragging Equipment Detector (DED)

The dragging equipment detector detects any object hanging under a car or 

locomotive. The DEDs may be of two different designs; paddle (mechanical) style, 

Figure 16, or impactor (electronic) style, Figure 17. The paddle style consists of strike 

plates, both 

Figure 15: Typical Location of Hot Box Scanner on Field Side of Track 

Figure 16: Paddle style DED Figure 17: Impactor style DED showing 

location of an accelerometer on 

the underside of the strike plate
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inboard and outboard of the rails, attached to a shaft with a cam-operated switch and a 

return spring. An object striking the paddles in either direction would rotate the shaft, 

momentarily opening the switch contacts. An open circuit would trigger an alarm. The 

impactor style is designed to alleviate the problems associated with the paddle style 

under deep snow conditions and has no moving parts. Stationary strike plates between 

and outboard of the rails are fitted with accelerometers which detect impact energy. 

Sufficient impact energy creates an electrical output that generates an alarm. 

 Hot Wheel Detector (HWD)

The function of hot wheel detector is to detect overheated wheels. Abnormally high 

temperatures indicate brake pads stuck to wheel treads. This condition causes a 

significant increase in friction resulting in hot wheels indicating brake problems. The 

HWD is similar to the HBD in that it senses radiant heat energy using infrared scanner 

technology. However, the target in this instance is the wheel plate area near the tread, 

approximately 2 1/2 inches above the rail, Figure 18. Some systems use an HWD 

scanner on both sides of the track, but most use only one scanner on one side of the track. 

When only one HWD scanner is used, Figure 19, to scan wheels on both the near and far 

rail, it is normally set at an angle to the track. The outboard wheel plate surface of a 

wheel on the near rail can be scanned, as can the inboard wheel plate surface of a wheel 

on the far rail. A reference temperature is established by placing a white board on the far 

side of the track opposite the HWD scanner. The reference board is used as a base value 

in order to produce semi-absolute wheel plate temperature readings. These readings are 

then compared to preset alarm thresholds. 

 If a wheel is cold during brake application, e.g., in a run going down the grade, then its 

 brakes are not working correctly. 

Figure 18: A Typical Arrangement of Infra-red Sensor for Sensing Wheel Plate Temperature 
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 Load Imbalance and Overload Detector (LIOD)

These detectors are used to reduce derailment conditions and infrastructure damage by 

measuring vertical loads on all wheels of a car at track speeds; and consequently from 

these measurements detecting and alarming for overloaded rail cars or imbalanced rail 

cars, Figure 20. Since only vertical wheel loads are of essence for these detectors, 

Figure 21, they lend themselves well as add-on capabilities to the Wheel Impact Load 

Detectors. However, stand-alone wayside installations of these detectors may 

 sometimes be required. Using statistical analysis of multiple vertical load 

 measurements recorded by the detector, an estimate of the static weight of a rail 

car is derived to determine if the rail car is overloaded or imbalanced beyond safe 

operating limits. 

These detectors may also provide the weigh- in-motion capability at track speed so that 

the need to take individual rail cars out of service for weighing is reduced. The 

corresponding weigh- in-motion measurements may however be affected by defective 

wheels, and sometimes by hunting trucks or other degraded conditions that reveal 

themselves in the process. As such the weighing accuracy of these detectors, as 

compared to the low speed or revenue-scale weigh bridges, is debatable. Their use as 

alternative weigh-in-motion systems is the prerogative of the railroads, their customers 

and the AAR. 

Figure 19: A Super Site on Revenue Track showing HWD, HBD and DED. The HWD 

has only One Scanner at an Angle to the Track with a White Reference Board 

on the Far Side. 
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 Truck / Bogie Optical Geometry Inspection (TBOGI) 

Figure 20: A Case of Imbalance Loading of car 

Figure: 21: Shown LIOD consists of an Angle Iron bolted to Rail at every Tie 

Location and also anchored with Rail to Ties with Elastic Clips. The 

Angle Iron is instrumented on Crib Locations to measure Wheel 

Loads. As shown, the LIOD can be detached and anchored as needed. 
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Wear of the worn wheels on an axle will always be non-symmetrical. Maintenance of 

trucks then requires that this non-symmetry in wear of profiles of wheel-pairs on axles of 

the truck be reduced to a minimum. The TBOGI, by monitoring bogie performance on 

straight track, provides means to access the asymmetric wheel-pair wear of an axle in 

terms of racking position (TP), inter-axle misalignment (IAM), tracking error (TE), truck 

rotation and truck shift, Figure 22. The TBOGI is a laser-based inspection system 

manufactured by WID Inc. that scans trains passing at track speed to determine by 

optical means the geometric faults in the alignment and tracking of bogie wheel sets on 

straight (tangent) track. 

The TBOGI operates on the tangent track eliminating the need for a special track layout. 

Non-contact laser sensors are installed at a safe distance, Figure 23, from passing trains 

in order not to interfere with any track maintenance work. The measurement method 

embodied in TBOGI provides a wide dynamic range and yields consistent results. Wide 

dynamic range allows TBOGI to identify very subtle bogie performance deficiencies 

while also capturing gross defects. The consistency of data provided by TBOGIE allows 

users to trend the health of rolling stock, thereby enabling the scheduling of maintenance 

interventions to correct impending defects before an exception is raised or other damage 

is caused. 

Figure 22: Definitions of Possible Displacements and Rotations in a 

Moving truck 
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The features of TBOGI include 

 Identifies skewed and “warped” trucks. 

 Identifies misaligned trucks. 

 Identifies trucks with incorrect wheel set tracking. 

 Identifies trucks that wear their wheels asymmetrically (“diagonal wheel wear”) even 

before severe wear sets in. 

 Identifies trucks displaying lateral instability “truck hunting.” 

 Non-contact sensors installed at a safe distance from passing trains do not interfere 

with track maintenance work. 

 Installed on tangent track, no need for special track layout. 

 Measurements are insensitive to change in weather and rail lubrication conditions. 

 Measure at train speed up to 250 km/h. 

 Laser based sensor provides high accuracy wheel set angle of attack and tracking 

position information. 

Acting on data produced by the TBOGI can enhance safety, reduce wheel set 

replacement, prolong truck component life, reduce rail wear, reduce fuel consumption, 

and optimize maintenance resources. 

Figure 23: Typical TBOGI Deployments in Freight Revenue and High Speed Amtrak 

Services 
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Preliminary Guidance for Interpreting Wayside Detector Data in Derailment Cause 

Finding / Prevention Related to Car/Equipment Only 

The distress to car/equipment arising from operations involving imbalanced loading, 

overloading, misaligned trucks, increased grade, warped trucks, hollow wheels, out-of-round and 

flat-spot impacts, curved track, stuck brakes, impacts at bridge approaches, diamonds, switches, 

and rail joints can be monitored by wayside detection technology according to the three 

following strategies: 

1) Wayside condition detections 

a. Cracked Axle Detector (CAD) 

b. Cracked Wheel Detector (CWD) 

c. Thermal Scan (TS) 

d. Acoustic Bearing Detector (ABD) 

e. Low Air-hose Detector (LAD) 

f. Dragging Equipment Detector (DED) 

2) Wayside performance detections 

a. Truck Hunting Detector (THD) 

b. Truck Performance Detector (TPD) 

c. Wheel Impact Load Detector (WILD) 

d. Overload/Imbalance Load Detector (OILD) 

e. Warm Bearing Trending (WBT) 

f. Wheel Temperature Trending (WTT) 

3) Wayside machine vision technologies 

a. Wheel Profile Module (WPM) 

b. Brake Shoe Module (BSM) 

c. Automated safety appliance inspection system (ASAIS) 

d. Automated inspection of system components (AISC) 

FRA has no regulations pertaining to the data collected by wayside detectors at present. As such, 

all that FRA can do is to use this data, along with the railroads, in finding the causes of distress 

to equipment and infrastructure. To aid in this effort AAR’s Field manual provides guidelines on 

detector calibrations and thresholds on collected data. Some of these thresholds, e.g. for WILD 

and THD, are also mentioned in prior detector descriptions. As an example, the AAR 

condemnable alert (WILD - 90 kips to less than 140 kips for single wheel) represents the regular 

Field Manual Rule 41 condemnable level at any time. The final alert level (WILD – 140 kips and 

greater for single wheel) represents a wheel having an impact force on the rail so great that it 

places undue stress on both the wheel and the rail. 

Hunting usually occurs on empty cars at speeds greater than 50 mph. Truck hunting detector 

limits are given in Interchange Rule 46. The responsible party is notified through the EHMS 

system when a car has a truck with a single THD detector reading (Salient Systems force-based 

Truck Hunting Index (HI)) greater than or equal to 0.20. This is considered the Window of 

Opportunity when car is in home shop. However, condemnable at any time using THD detector 

data is defined when either 1) a single HI absolute value reads above 0.65 or 2) two HI absolute 

values read above 0.50 in a twelve month time period. Rule 46 requires that home shop 
Motive Power and Equipment Compliance Manual 

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disposition be requested from the car owner when a truck exceeds condemning limits detected by 

a THD wayside detector. Consequent corrective steps require that a) the affected trucks be 

qualified and/or repaired to AAR Specification M-214, b) condemnable friction wedges be 

replaced, c) if equipped with constant contact side bearings, resilient or spring elements be 

replaced, d) roller or block type side bearings be replaced with AAR M-948 approved long travel 

steel capped constant contact side bearings, and d) side bearing adjustment or component 

replacement be made per Rule 62. New sections were added to Field Manual Rule 46 addressing 

truck inspection and repair, and especially side bearing adjustment and repair Rule 62. 

AAR Field manual Appendix F addresses WILD and THD detector calibration, validation and 

data requirements. The truck performance detector (TPD) alert criteria are given in Field Manual 

Rule 46. 

Rules related to the acoustic roller bearing defect detectors (ABD) were added to Field Manual 

Rule 36. Appendix G covers initial and continuous ABD wayside detector site validation. Field 

Manual rule states that an ABD wayside detector Level 1 alarm represents a specific minimum 

amount of bearing damage corresponding to at least one of the following: 

 Two square inches or more of spalled area on any one cup or cone running surface, 

 One square inch of spalled area on any one cup or cone running surface and 1⁄2 square 

inch or more of spalled area on any one other cup or cone running surface, 

 Any orange peel surface (resembling the look and texture of an orange), 

 Any roller spall or seam, 

 Any loose component indication 

o Cone race backface wear greater than 0.010 inch 

o Indication of spun cone on the corresponding axle journal 

o Oversize cone bore from dynamic growth and evidence of turning on axle journal, 

 Two square inches or more of heavy water etched area, with indented surface(s), on cup 

or cone running surfaces. 

If an ABD wayside detector shows a Level 1 alarm on a bearing, the car can be sent to a repair 

track to perform a hand roll inspection for removal or further inspection. As a rule of thumb, the 

reasons of hot bearings attributable to various failure progression modes, in descending order of 

magnitude or significance, are: 

 Water etch 

 Loose 

 Fatigue spalling 

 Bearing destroyed 

 Wheel defect 

 Mechanical 

 Adapter 

 Lubrication 

 Displaced seal 

 Application 

 Truck related 
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 Manufacturing defect. 

Of these above modes, spalling and water etch are detected easily by acoustics. ABD wayside 

detectors are an evolving technology such that with additional development, some percentage of 

the other failure modes may also be detectable acoustically. 
A – 1 

Appendix A

Instructions for Completing MP&E Violation Reports

Motive Power & Equipment Technical Bulletin MP&E 05-01, Guidelines for Preparing 

New MP&E Violation Reports – FRA, F6180.109 "Motive Power & Equipment 

Violation Report Form" which is embedded below under header Motive Power & 

Equipment Report Form F 6180.109 is used for violation reports covering 49 CFR 

Parts 209, 210, 215, 223, 224, 229, 230, 231, 232, 238, 40 CFR Part 201, (Noise 

Violations, EPA), and Statutory Violations of USC 49 Subtitle V Chapters 203 & 207. 

MP&E violation recommendations associated with Part 218 and 221 will use Form FRA 

F6180.67. 

Form FRA F 6180.109 and a help guide are components of the RISPC program, and can 

be accessed from within RISPC or the shortcut icon. The software automatically 

transfers some of the information from the F 6180.96 Inspection Report over to Form F 

6180.109. 

Note: A narrative section is still required and shall be inserted in Item 44 (Violation 

Narrative) of the form. Any attachments such as photographs or other supporting 

documentation should be included in the F 6180.109 package. 

Executive Order – 13589/ Section 5 dated November 9, 2011, Promoting Efficient 

Spending requires agencies to reduce costs associated with printing and shipping. Hence, 

inspectors are required to create paperless digital documents of violations for submitting 

to the regional specialist. This process is intended to provide uniformity in submitting 

digital violations throughout the FRA. All applications used by MP&E field inspectors, 

such as Microsoft Word, Microsoft Excel, Photographs, etc. can be converted into a PDF 

file. This is “built-in” to the application in either the file pull-down menu, printing, or 

the toolbar. It allows the current document to be converted into a PDF file, which will 

be saved as the digital violation. 

If you have any questions regarding the use of this form or the process by which to 

complete the digital violation, please contact your Regional Specialist.

The RISPC Program, F6180.96 and Forms F6180.109; F6180.67 Forms

F6180.96 Inspection Report preparation is mandatory for all inspections where a civil 

penalty action (violation report) is recommended. Inspectors should complete the 

Remedial Action portion of the inspection report, as soon as the report (railroad copy), is 

received from the railroad. Federal regulations require railroads to submit notification 

of Remedial Action to FRA for all violations 30 days after the end of the calendar month 

in which notice of violation occurred. In this regard, it is recommended that Inspectors 

update all inspection reports containing violations on a regular basis to help ensure the 
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integrity of FRA’s inspection report database. When using the RISPC inspection report 

program, some of the items will automatically transfer from the F6180.96 inspection 

report to the F6180.109 and F6180.67 violation report. 

Submission of Photographs as Evidence

Photographs can sometimes be very strong evidence in support of a violation. If 

photographs are included in the violation, the inspector will attach each photograph using 

a medium which can be converted to a digital attachment (PDF file) and explain what 

each photograph shows. Photographs which have been altered in any way should not be 

included as violation evidence. In addition, be certain that the photo clearly depicts the 

defect and location of the defect(s) in question. 

Statements of Witness or Reports of Interview

Unless a violation is substantiated by an Inspector’s personal knowledge or by records 

FRA requires railroads to maintain, the violation report should be accompanied by 

Statements of Witness report(s) obtained from railroad employees, railroad officials, or 

other persons who know the circumstances surrounding the non-complying act or 

condition. It is preferable to use Witness Statements rather than Reports of Interview in 

violations. 

If Reports of Interview must be attached to violation reports, care must be exercised as 

this could result in unintentional FRA non-compliance with the requirements of Public 

Law which prohibit disclosure of railroad employees who report railroad safety violations 

without their written consent. When using Reports of Interview to help ascertain the 

facts, policy requires the Inspector must: 

 Advise the person that the interview is voluntary; 

 Advise the person that the interview will be attached to a violation report and 

submitted to the railroad or company when a penalty demand is issued; and 

 Prior to submission, the interview report must be validated by the person being 

interviewed. This can be accomplished either by mail or hand delivery. 

Each Witness Statement or Report of Interview must contain the time, date, full name, 

title, and mailing address of the person who was interviewed. 

Copies of Railroad’s Records

When applicable, the violation report must be accompanied by legible copies of the 

railroad’s applicable records, containing information that will provide the FRA’s Office 

of Chief Counsel with substantiating documentation and a clear understanding of the 

violation of Federal safety regulations. 

All supporting documents to the violation must be scanned and included as a PDF file or 

Master File, which is the complete digital violation package.
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Digital Violation Master File 

Use of the mandatory master filename format to name the violation package is as follows 

and the case type list you will need is included.

File Format:

Region-Case Type-Inspector initials-Violation No. 

Example: 

R5-FCS-DC-200.pdf 

Case Type List

Code Type

AD Alcohol and Drug Regulations

AR Accident Reports Regulations

BW Bridge Worker Safety Standards

EO FRA Emergency Order

EP Railroad Enforcement Procedures

EQ Engineer Qualification Regulations

FCS Freight Car Safety Standards

GC Grade Crossing Signal Safety Regulations

GS Safety Glazing Standards

HMT Hazardous Materials Regulations

HS Hours of Service Laws

HSR Hours of Service Record Keeping Regulations

LI Locomotive Safety Standards and Statutes

LIS Steam Locomotive Safety Standards and Statutes

PEP Passenger Train Emergency Preparedness Regulations

PEQ Passenger Equipment Safety Standards

REM Rear End Marking Device Regulations

ROP Railroad Operating Practices

ROR Railroad Operating Rules

RSP Railroad Communications Regulations

RW Roadway Worker Protection Regulations

SA Safety Appliance Statutes and Regulations

SI Signal Inspection Regulations and Statutes

TH Train Horn/Quiet Zone

TS Track Safety Standards
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List of Exhibits Requirements 

1. The exhibits list should not be labelled as an “Attachment List”.

2. The Exhibit List must be a separate document titled “List of Exhibits”.

3. Inspectors MUST NOT place the Exhibit list in the narrative of the Violation Report.

4. List all of your exhibits in order of relevance. 

Identification of Exhibits

All documents/pages, including each exhibit that is in your violation package must 

contain a means of identification (ID). This ID is to be placed in the lower right hand 

corner of each page of the document. 

Note: Inspectors must use the following mandatory identification process.

Inspector Initials – Violation No. 

Example: DC-200 

Sequence of Master Digital Violation

Inspectors must use the following arrangement when completing the master digital 

violation. 

 Violation Report F6180.109 (not and exhibit) 

 List of Exhibits Page with exhibits noted in order of relevance.

 Inspection Report F6180.96 – Railroad Copy 

 Other attachments as noted on “List of Exhibits” page in order of relevance. 

PDF Violation Package – Bookmarking Documents

Violation packages are required to have bookmarks embedded in the Master File that will 

identify each exhibit or document separately.

This process can be accomplished using the Adobe program once the violation package 

Master File is complete. 

Violation Package

The entire violation package contains the following: 

 TFR – F6180.72x (transmittal form). 

 Cover letter regarding extraordinary penalties (if applicable).

 Master violation report file.

Note: Bullets one and two are separate files and do not require digital signature by the 

inspector. 
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Digitally Signing the Completed violation Package

Inspectors are expected to sign the completed violation package with a digital signature. 

However, the violation package will be accepted with a written signature that is scanned 

into a PDF document, but FRA would prefer a digital signature. 

This process can be accomplished using the Adobe program once the violation package 

Master File is complete. 

Motive Power & Equipment Violation Report Form F 6180.109

Each of the 47 Items and Field descriptions/requirements are outlined in detail. 

Item/Field

1. Subject: The program will automatically generate this field when the CFR/USC entry is 

made in Item #2. Completion of this field is mandatory. 

2. Violation Of: Check the appropriate box (e.g., 40 CFR. 49 CFR or Statutory Section). 

Enter the exact Part, Rule, and Sub-rule for the violation of the CFR. The CFR, Rule, and 

Sub rule will be automatically generated from the inspection report line item, but may be 

changed. The CFR and Rule will be checked against the RISPC CFR reference file. 

Only one line entry is allowed in this field. Completion of this field is mandatory. 

3. Report No.: This field is entered for each violation report. Any report number will be 

accepted as long as it does not create a duplicate report. The report number can only be 

edited from the start window. It cannot be edited once the violation form is open. 

4. Related Viol.Rpt.No. (s): Related violation report numbers should only be entered when 

multiple violations are issued and related to one another, (e.g., more than one locomotive 

or car in the same train movement). Completion of this field is optional. It can contain up 

to 20 characters.

5. Inspection Report No.- Report Date: This field is auto-populated from the F6180.96 

Inspection Report. Inspection reports are required for all violations, a violation report 

may not be prepared unless a corresponding inspection report has been created and 

present on the hard drive. This is a non-editable field. 

6. Additional Regulations Violated: If applicable, enter other sections of the CFR or 

Statute that the locomotive or car may be in violation of. Since field 2 will only allow for 

one line of text, this field is the location where additional sections of the CFR may be 

cited. Locomotives and cars with multiple defective conditions could affect the aggregate 

amount of civil penalty assessed on a railroad. Completion of this field is optional. It 

consists of four sub-fields, with 23 characters per sub-filed. If additional space is needed, 
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Α − 6

use the narrative section (Item 44), to detail additional regulations violated. When 

inspectors create the MP&E Violation Form F6180.109, they may choose to include from 

the inspection report up to four additional line items in Item #6 for the same locomotive 

or car. 

7. Operating Railroad: This field is auto-populated from the F6180.96 Inspection Report. 

It may be changed, but it may not be left blank. 

8. RR Initials: This field is auto-populated from the F6180.96 Inspection Report. It may be 

changed, but it may not be left blank. 

9. Railroad Division: This field is auto-populated from the F6180.96 Inspection Report. 

This is a non-editable field.

10. Name of Inspector(s): This field is auto-populated from the F6180.96 Inspection Report. 

The name of the primary inspector cannot be edited. Clicking and entering the 

appropriate names directly into the field may enter two additional inspectors’ names. 

Each sub-field can hold up to 25 characters. 

11. ID Number: This field is auto-populated from the F6180.96 Inspection Report. This is a 

non-editable field. Only one inspector ID is necessary for this field. 

12. Date(s) of Violation: This field consists of two sub-fields. Completion of the top field is 

mandatory and is auto-populated from the F6180.96 inspection Report. The default date 

will be the same date used on the inspection report. However, if it is necessary to change 

the date, click on the arrow and select the appropriate date from the drop down calendar. 

The date of the violation may not be later than the inspection report date in item #5. The 

second sub-field can hold up to 25 characters and should only be used when citing 

violations for multiple days.

13. Time of Violation: This is the time when the violation occurred based on personal 

observation, Statement of Witness (signed), or records. Click in the field and enter the 

appropriate time. This field is limited to 20 characters. Completion of this field is 

mandatory. 

14. Inspection point: This field is auto-populated from the F6180.96 Inspection Report. This 

is a non-editable field.

15. Track No. / Name: Enter the appropriate track number or track name by clicking and 

entering the appropriate information. Completion of this field is optional. 

16. Location of Inspection (City, County & State): This is the location where the 
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inspection was made. This field is auto-populated from the F6180.96 Inspection Report. 

The default City and/or County and State will be the same City and/or County and State 

used on the inspection report. For some violations, this location may differ from the 

location indicated in Item 17, (e.g., inbound train movement violations). The State code 

will be the two-character abbreviation. This is an editable field. Note: For violations 

based on signed witness statements, this is the location where the witness observed the 

violation. The location information entered here must be valid. 

17. Location of Violation (City, County & State): This is the location where the violation 

occurred. This field is auto-populated from the F6180.96 Inspection Report. The default 

City and/or County and State will be the same as Item 16. The State code will be the 

two-character abbreviation. This is an editable field. Note: For violations based on signed 

witness statements, this is the location where the witness observed the violation. The 

location information entered here must be valid. 

18. City, County & State Where Equipment Originated: Enter the City and/or County and 

State where the locomotive, car, or train originated. This information may be the same as 

indicated in Item 16 or 17. The purpose of this field is to identify where the train received 

its initial terminal inspection and test. Completion of this field is mandatory if the 

violation is related to defective equipment or if Item 21 is completed. The location 

information entered here must be valid. 

19. Location Where Locomotives Are Maintained and Previous Periodic & Daily 

Inspection Information: This field consists of three sub-fields. For locomotive 

violations, enter the City and State where the locomotive is maintained or assigned (if 

applicable), in the top line or first field. This field is limited to 25 characters of text. The 

second line requires information pertaining to the previous periodic and daily inspection. 

Enter the appropriate Date, City, and State for each. The information for this field should 

be obtained from form F6180.40A and daily record on the locomotive. Previous periodic 

and daily inspection information is mandatory if the subject of the violation is related to 

Parts 229 and 230. The dates entered here must not be later than the inspection date. The 

location information for previous periodic and daily inspections must be valid.

20. Line Item: This field is auto-populated from the F6180.96 Inspection Report. When the 

violation program is launched, the user is required to choose from the reference table 

which line item to import from the inspection report. Once this action is complete, 

pertinent data from the inspection report will auto-populate this field as well as the 

information required for Items 21, 22, & 23 when applicable. Completion of this filed is 

mandatory. 

21. Equipment Initials & No.: This filed is auto-populated when applicable from the 

F6180.96 Inspection Report. This is a non-editable field. 
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22. Equipment Description: This filed is auto-populated when applicable from the 

F6180.96 Inspection Report. This is a non-editable field. 

23. Train ID: This filed is auto-populated when applicable from the F6180.96 Inspection 

Report. This is an editable field and must be completed if field 32 is checked yes. 

24. Type of Service: Check the appropriate box. Completion of this field is mandatory. 

25. Name of Defective Component: Manual entries may be entered directly into the field. 

Use descriptions from the CFR to identify the defective component whenever possible. 

Completion of this field is mandatory if fields 21 and 22 are completed. This field is 

limited to 150 characters of text.

26. Location of Defective Component: Manual entries may be entered directly into filed. 

Enter a description that clearly explains the location of defective component. For 

example, “Facing side of car to the left” or “Facing end of car to the left”. It is also 

appropriate to use AAR descriptions to locate a particular appliance on a locomotive or 

freight car. For example, “Left front bottom switching step, “ or “AR sill step.” 

Completion of this field is mandatory if fields 21 and 22 are completed. 

27. Equipment Status: This filed will be completed from a drop-down menu that will 

contain eight commonly used canned descriptions. Completion of this field is mandatory 

if field 21 and 22 are completed. This field is limited to 80 characters of text should the 

inspector need to use other than one of eight canned descriptions. 

28. Position of Equipment and/or train with Relation to Some Fixed Object at Time of 

Inspection and/or Violation: Orientate the equipment or train with a fixed object in the 

yard or track at the time of violation. For example, BNSF 8888 on main track 200 feet 

east of the yard office. If unknown indicate “Unknown.” Completion of this field is 

mandatory. This field is limited to 130 characters of text.

29. Defect is: Check the appropriate box. Completion of this field is mandatory if field 21 

and 22 are completed. 

30. How Long Had Equipment Been At Place of Violation: Enter the amount of time the 

equipment in violation of federal Regulations had been at the location identified above. 

For example, if the equipment observed in violation had just arrived in a train, enter “just 

arrived.” If the equipment in violation has been there for about two hours from the time 

of initial observation and then departs in a train enter “Approximately two hours to my 

knowledge.” Completion of this field is mandatory if fields 21 and 22 are completed. 
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Α − 9

31. Equipment Marked for Repairs: Check the appropriate box. This also includes 

automated tracking. Completion of this field is mandatory if fields 21 and 22 are 

completed.

32. Failure to Perform Air Brake Test: check the appropriate box. Completion of this field 

is mandatory. 

33. Type of Brake Test Required: Click on the arrow to select the appropriate subject text 

from the drop down list. The text chosen for this field must be selected from the drop 

down list, manual entries are not allowed. Completion of this field is mandatory when 

filed 32 is checked “Yes.” 

34. Brakes Overdue for Periodic Attention: check the appropriate box. Completion of this 

field is mandatory.

35. Brakes overdue for Single Car Test: Check the appropriate box. Completion of this 

field is mandatory.

36. SCT Device Available: Check the appropriate box. Completion of this field is 

mandatory. 

37. Time: this field consists of four sub-fields for entering times relating to improper brake 

test or trains operating with inoperative brakes or has air brakes due for periodic 

attention. Enter the appropriate times under each of the sub-fields. If the brakes were 

never applied or released, enter a hyphen (-). Completion of this field is optional, but 

must be completed when violation is related to improper brake test and/or trains 

operating with inoperative or has air brakes due for periodic attention. Each sub-filed is 

limited to eight characters of text.

38. Trains Consist – Locomotives – Cars – Operative Brakes: This field consist of six 

sub-fields for entering information relating to train make-up and percentage of operative 

brakes. When entering the percentage of operative brakes, be sure to use the appropriate 

calculations. The calculation methodology differs between passenger and freight 

operations. Completion of this field is optional, but must be completed when violation is 

related to improper brake test and/or trains operating with inoperative air brakes. The six 

sub-fields are limited to the following characters of text, from left to right: 9, 2, 3, 3, 3, & 

4. 

 

39. State Facts Which Determine Type Of Air Brake Test Required: Manual entries may 

be entered directly into the field. Enter an appropriate statement that definitively 

describes the type of brake test required. For example, in the case of brake(s) cutout, 

inoperative or failure to perform and Initial Terminal Brake Test, the correct entry would 
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Α − 10

be “Train originally made up at this point.” Completion of this field is mandatory when 

filed 32 is checked “Yes.” This filed will accommodate as much text as desired by user. 

The preferred typing “font” and size is “Times New Roman” size 12. 

40. Description of Use, Movement or Events Constituting Violation: Manual entries may 

be entered directly into the field. Use descriptions that affirmatively describe observed 

use or movement of equipment. With the exception of the Glazing and Nose standards, 

actual movement of equipment is not necessary for the railroad to be in violation of FRA 

regulations. However, violations citing actual movement will generally make a stronger 

case for railroad safety. Completion of this filed is mandatory. This filed will 

accommodate as much text as desired by user. The preferred typing “font” and size is 

“Times New Roman” size 12.

41. Describe Repair Facilities: Indicate whether or not repair facilities are available. 

Provide a detail description of the facilities available. For example, if a location only has 

wheel trucks available for making repairs provide what type of equipment (tools, 

compressed air, welding equipment, etc. is available). If a location has a fixed repair 

facility, provide as many details regarding what type of repairs are made to equipment on 

a daily basis. If repair facilities are not available indicate “None.” Completion of this 

filed is mandatory. This filed will accommodate as much text as desired by user. The 

preferred typing “font” and size is “Times New Roman” size 12. 

Note: If “None” is entered be certain to explain in detail under Violation Narrative why 

the locomotive, power car, or car (passenger or freight), is in violation of Federal 

Regulations. The laws and regulations related to safety Appliances require defective 

safety Appliances to be repaired when found to be defective. However, the law does 

allow for the movement of defective Safety Appliances to the nearest location where the 

necessary repairs can be made if repairs cannot be made in a safe and reasonable manner

at the location where they are originally found defective. Prevailing case law suggest that 

neither knowledge of the defect(s) nor convenience mitigates a railroad’s responsibility 

for compliance with the Safety Appliance Laws and Regulations. The key here is whether 

or not repairs can be made at the location where the equipment is originally found 

defective in a safe and reasonable manner. If a wheel truck at a particular location 

routinely makes repairs of the type needed, then FRA will generally consider that 

location a location where those repairs can be made. Conversely, FRA does not expect a 

railroad to conduct repairs at a location that exposes its employees to unnecessary danger 

or risk of personal injury. Thus, inspectors are reminded to consider these fact and weigh 

the circumstances carefully when determining “safe and reasonable.” 

(For a listing of factors to consider when determining whether a location is one where 

repairs can be made, see the new Power Brake Regulations at 232.15(f).) 

42. Description of Non-compliance: Manual entries may be entered directly into the field. 
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Α − 11

This field must contain a detailed narrative description pertaining to the issue in 

non-compliance. For safety appliance violations, use any of the following three adjectives 

to describe the defective condition, inoperative, ineffective, or insecure. For example, 

“Insecure end-handhold account one of two fasteners missing, or “ineffective 

end-handhold account 14” of its 16” clear length crushed against the car.” Completion of 

this filed is mandatory. This filed will accommodate as much text as desired by user. The 

preferred typing “font” and size is “Times New Roman” size 12. 

43. Railroad Response or Remedial Action Taken in Response to Violation: Manual 

entries may be entered directly into the field. Be certain to describe any agreement or 

disagreement with respect to findings and notification of violation and note remedial 

action taken by the railroad. Completion of this filed is mandatory. This filed will 

accommodate as much text as desired by user. The preferred typing “font” and size is 

“Times New Roman” size 12. 

44. Violation Narrative: In chronological order, write a thorough description of the 

violation. This should include factual information that clearly articulates the violation in 

detail, as well as a summary of defects observed in the train. Describe all circumstances 

surrounding the violation, such as movement, use or prior inspection by railroad 

mechanical forces. Use statements such as “I observed” or “This violation is based on 

personal observation.” 

Consider including details that will counter any mitigating factors that railroad attorneys 

might submit during claims conferences. For example, if the violation is reoccurring and 

the inspector has had little or no success in achieving compliance with the railroad or 

individual, it would be extremely important for the inspector to include details about 

compliance history if not adequately detailed in field 44. 

The inspector may quote a portion of the applicable regulation if this will assist the 

reader’s understanding of the nature of the violation. This filed will accommodate as 

much text as desired by user. The preferred typing “font” and size is “Times New 

Roman” size 12. 

Note: If known, include a brief description of the overall compliance history at location 

where inspection and/or violation occurred. Enter, in percentages if possible, the overall 

compliance history for the last year and current year at the location where the violation 

occurred. It is also acceptable to use narrative descriptions to illustrate situations 

concerning current and/or past egregious and/or recurrent non-compliance.

45. Date of Report: Enter date the violation report was prepared. Completion of this field is 

mandatory. This date may not be earlier than the inspection date. 
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46. Signature of inspector(s): At a minimum, the first two copies of the report should bear 

an original signature of the inspector(s), preferably in blue ink. Inspectors are expected to 

sign the completed violation package with a digital signature. However, the violation 

package will be accepted with a written signature that is scanned into a PDF document, 

but FRA would prefer a digital signature. 

47. Railroad Notification: This field has four sub-fields for entering information relating to 

time, date, person and title of the railroad person notified about this violation. Enter the 

appropriate information. Completion of this field is mandatory. The notification date may 

not be earlier than the inspection date. 

Digital Violations FAQ

Below are the most commonly asked questions asked of FRA Chief Counsel (RRC) and 

answers provided. 

1. Q. Has FRA’s Office of Chief Counsel (RCC) and the Office of Railroad Safety 

approved this document and the new processes implied herein? 

A. Yes.

2. Q. How should I attach supporting documents (exhibits) to violations? 

A. Do not provide a list of supporting exhibits in the body of a violation narrative. 

Please use a separate sheet titled “List of Exhibits,” and list supporting exhibits without 

numbers or letters. Supporting exhibits should be listed and attached in order of 

relevance.

 

3. Q. Can inspectors reference a specific exhibit in the narrative of the violation even 

though inspectors were previously instructed NOT to put the “List of Exhibits” in the 

body of the violation itself? 

A. Yes. In fact, RCC strongly requests that inspectors should reference exhibits when 

it is needed to provide clarity. FRA attorneys will be in a better position to defend the 

merits of the violation because they will better understand the entire circumstances 

surrounding the case. Nonetheless, inspectors should be cognizant that if a specific 

exhibit is referenced in the narrative, and then that same exhibit is removed by RCC, the 

violation package will likely have to be returned to the inspector for editing.

4. Q. How should each document in the “List of Exhibits” be named and identified? 
Motive Power and Compliance Enforcement Manual

Α − 13

A. In the “List of Exhibits” inspectors should use a name that corresponds to what the 

exhibit actually is - e.g. Inspection Report, Train Consist, Hours of Service Record, Photo 

Sheet, etc. For the identifier, each exhibit should use the same identification procedure 

as the other documents in the violation package. That identifier should be in the lower 

right hand corner and formatted as: Inspector’s initials-violation number, e.g. PLM-121. 

5. Q. Is it necessary to attach an entire train consist, timetable, track chart, etc. when 

using a voluminous document as an exhibit? 

A. No. Only attach the relevant pages such as the cover page and the actual page(s) 

needed to support the violation. Inspectors should be sure to provide a clear 

explanation of the relevance the exhibit has to the violation. This explanation should 

include where and when the inspector obtained the document. This is necessary in the 

event that the railroad produces conflicting documents. 

6. Q. Are there any special considerations I should be aware of when preparing violations 

associated with complaints?

A. Yes. Nothing in the violation report package should reference the complainant’s 

name, complaint control number, source code, or the fact that the violation is based on 

information obtained from a complainant. The only exception is when the violation 

report is accompanied by a signed witness statement on the approved form. Note: 

Inspectors should only attach the Railroad Copy of the F6180.96 to the violation report 

package, not the FRA Copy. 

7. Q. Is it necessary to wait for the Remedial Action report to be completed by the railroad

prior to submitting the violation package? 

A. No, but inspectors should always attempt to resolve remedial action reports in a 

timely manner.

8. Q. Is the F6180.96 Inspection Report valid without a signature from a railroad official? 

A. Yes. An inspection report does not need a railroad official’s signature to be 

considered valid. However, inspectors should endeavor to obtain the railroad official’s 

signature acknowledging receipt of the report when practicable, and must always 

indicate in the violation report the name and title of the railroad official notified of the 

violation. This signature should be obtained on the Railroad Copy of the F6180.96. 

9. Q. Can FRA inspectors accept an e-signature of the railroad official on the F6180.96 

Inspection Report? (Like an Adobe e-signature, or similar)
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Α − 14

A. Yes. Also, a copy of a “read receipt” indicating the railroad official received the 

report via email is adequate and can be included in the violation package. A “read 

receipt” can be requested when the FRA inspector sends the railroad official an email 

with the F6180.96 report attached. The “read receipt” could then be printed out or saved 

as a PDF file.

10. Q. Regarding Remedial Action of 209.407, can FRA Inspectors accept an e-signature 

from a railroad official when the railroad sends a “Delayed Report” regarding why their 

remedial action is delayed.

A. No. Technically, 209.407 requires the delayed report be signed, dated and mailed 

via first class mail to the FRA inspector within 30 days after the end of the calendar 

month in which the notification is received. 

11. Q. Can FRA inspectors use Adobe’s e-signature in lieu of scanned copies of violation 

reports and inspection reports that contain original, handwritten signatures?

A. Yes.

12. Q. If I can’t sign my name digitally, will RCC still accept a document that I have 

signed and then scanned into the violation report? 

A. Yes.

13. Q. Should a Form 8 (Special Notice for Repair) be included in the violation report 

package?

A. Yes, as well as the Form 8A, if available. 

14. Q. How do I handle electronic media (wav files, videos, etc.)? 

A. RCC will handle on a case-by-case basis (regional management should inquire to 

RCC for guidance). 

15. Q. Is it necessary to create a separate 6180.96 report for each violation cited when there 

are multiple violations found on a railroad or shipper that day? 

A. No. However RCC prefers to see all the defects associated with the violation on 

one inspection report. 

16. Q. Does the violation package have to be bookmarked? 
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Α − 15

A. Yes. 

17. Q. Is each document in the violation package required to contain a header identifying 

the document as pertaining to that specific violation? 

A. Yes. Use the required format: Inspector’s initials-violation number, e.g. 

PLM-121. 

18. Q. What is the difference between the digital violation package master filename and 

the identification of the documents in the digital violation package? 

A. The digital master filename identifies the violation package’s master PDF file. 

The identifier associates each document within the master PDF file with a common name, 

e.g. PLM-121, preferably in the lower right corner of each page. 

19. Q. Are there any documents that should not be included in the violation package’s 

master PDF file? 

A. Yes. Both the Transmittal Memo (TFR) and the memorandum addressed to RCC 

regarding any requested extraordinary penalties are separate documents and should not 

be included in the violation package’s master PDF file. 

20. Q. Are there any other resources that I can read to help me improve my violation 

reports?

A. Yes. Refer to the document in the General Manual entitled “Improvements in 

Civil Penalty Enforcement Memo – Dated June 18, 2009.” 

Contact your Regional Specialist if you have additional questions regarding Form F6180.109. 
 B – 1 

Appendix B

Motive Power& Equipment Waivers 

Electronic Locomotive Brakes

The following are waivers that apply to electronic locomotive air brakes, which extend the time 

periods specified in 49 CFR §§ 229.27(a)(2) and 229.29(a) for cleaning, repairing, replacing, and 

testing locomotive brake components. 

FastBrake–EPIC Electronic Locomotive Brakes

Re: Docket Number FRA-2002-13397 (Formerly H-92-3) 

Waiver FRA-2002-13397 (formerly H-92-3) was amended to include Wabtec’s next generation of 

the EPIC product line, the FastBrake electronic air brake system. This conditional waiver extends 

the time intervals for cleaning, repairing, and testing certain pneumatic air brake components listed 

in 49 CFR § 229.27(a)(2) and 49 CFR § 229.29(a) to 5 years. Any railroad can use waiver FRA2002-13397 for locomotives equipped with an EPIC brake system, as long as the waiver is properly 

identified on the locomotive blue card (Form FRA F6180-49A). Waiver FRA-2002-13397 is 

subject to the following conditions: 

1. WABCO shall furnish FRA a list of all locomotives equipped with the EPIC or FastBrake 

systems to include: the locomotive manufacturer, the locomotive reporting marks and the 

date that each locomotive entered service, along with a quarterly update of locomotives that 

are placed in service with the EPIC or FastBrake systems. 

2. WABCO shall submit to FRA a quarterly report listing air brake failures, both pneumatic 

and electrical, of all locomotives included in this waiver to include: type and date of failure, 

locomotive reporting marks, cause and resolution, and any parts replaced. 

3. All verified failures of pneumatic components shall be promptly reported to FRA prior to 

disassembly so that WABCO, the railroad, and FRA personnel can jointly witness 

disassembly of the failed component to determine the cause. 

4. FRA’s Staff Director for Motive Power and Equipment may select up to 16 locomotives 

each calendar year for testing. The locomotives selected shall be comprised of locomotives 

that have been in service for 1, 2, 3, and 4 years with the EPIC or FastBrake system. 

WABCO shall arrange with the railroads to select a date, time, and location for the test. 

FRA, WABCO, and railroad personnel will test the locomotive brake system using an FRA 

approved static locomotive air brake test procedure. If there are no failures, nothing further 

will be required. If any pneumatic valve fails the test on the locomotive, the failure will be 

verified on a test rack or on another locomotive. If failure is verified, all pneumatic brake 

devices will be removed from the locomotive for disassembly and inspection. 
Federal Railroad Administration 

B – 2 

5. FRA reserves the right to increase the number of locomotives tested as the total of 

locomotives subject to this waiver increases. 

6. The brake pipe vent valves shall be cleaned, repaired, and tested at a minimum of every 368 

calendar days. 

7. In addition to the current requirements of 49 CFR § 229.27(a)(1), all filtering devices 

associated with the EPIC or FastBrake system shall be cleaned, repaired, or replaced on a 

368 calendar-day interval. 

8. The air compressor shall be maintained to perform as intended with emphasis on detection 

of oil contamination of the main air reservoir. 

9. FRA reserves the right to modify or rescind this waiver at any time if failures or conditions 

so justify, or in the event of noncompliance with any of the conditions of this waiver. 

Computer Controlled Brake Locomotive Brakes

Re: Docket Number FRA-2000-7367 (Formerly H 95-3)

The Computer Controlled Brake (CCB) system is manufactured by the New York Air Brake 

Corporation (NYAB). Any railroad can use waiver FRA-2000-7367 for locomotives equipped with 

the CCB brake system, as long as the waiver is properly identified on the locomotive blue card 

(Form FRA F6180- 49A). The existing waiver (FRA-2000-7367) was first granted on September 

13, 1996, extending the time interval for cleaning, repairing, and testing pneumatic components of 

the NYAB CCB-I locomotive air brake system under 49 CFR § 229.27(a)(2) and 49 CFR § 

229.29(a) from 736 days to 5 years. On August 20, 1998, the waiver was modified to include 

NYAB’s CCB-II electronic air brake system. On March 11, 2005, FRA modified the existing 

waiver to include the new CCB-26 electronic air brake system, along with the CCB-I and CCB-II 

systems, subject to the following conditions: 

1. NYAB shall furnish FRA a list of all locomotives operating in the United States equipped 

with the CCB-I, CCB-II, and CCB-26 brake to include: the locomotive reporting marks, the 

date that each locomotive entered service, and a quarterly update of locomotives that are 

placed in service with the CCB brake. 

2. FRA reserves the right to have NYAB perform tests and conduct a teardown inspection of 

any failed pneumatic component of the CCB brake system with FRA personnel witnessing 

the tests and teardown inspection. 

3. At FRA’s discretion, NYAB, in conjunction with the railroads, shall perform a functionality 

test of the CCB brake system on selected locomotives. If any pneumatic valve fails the test 

on the locomotive, the failure will be verified on a test rack. All pneumatic brake devices 

will be removed for disassembly and a visual inspection. 
Motive Power and Equipment Compliance Manual 

B – 3

4. NYAB shall coordinate with each affected railroad to identify complete CCB sets from the 

same locomotive for an evaluation of the CCB brake equipment at the 5-year periodic 

interval, using NYAB Test Plan ABT-3164 or an FRA approved substitute. Every effort 

should be made to collect original equipment by identifying locomotives in which the CCB 

sets have had no component replacement during the 5-year service life. If this is not 

possible, a detailed air brake service report from the railroad must be provided. 

5. Test Plan ABT-3164 or an FRA-approved substitute shall be used to test 10 sets of 

CCB-26 material in a NYAB test facility at the conclusion of 5 years in service. All failures 

identified in the test shall be put through the NYAB Failure Analysis process to determine 

the root cause. All components (whether pass or fail) will be torn down and visually 

inspected with documented photographs of the sub-components. Rubber will be tagged and 

retained for 1 year in case further analysis is required or requested. FRA reserves the right 

to have FRA personnel witness the tests and teardown inspections. 

6. Reports of each set tested will be summarized and provided to FRA and the appropriate 

railroad. This report will include the locomotive number, in-service date, history of repairs 

and field modification (FMI) activities, date any material was removed, and the testing and 

teardown results. The test reports will also contain all photos, test failures, root cause 

failure analysis (if required), and an evaluation of the effect of any failures upon the 

locomotive performance. 

7. NYAB shall notify FRA immediately of any significant trends of pneumatic and/or 

electronic failures (to include software problems), or any new problems that have not been 

previously identified, which affect the operation of the CCB equipment on any locomotive 

operating under this waiver. 

a. FRA reserves the right to increase the number of locomotives tested as the total 

number of locomotives subject to this waiver increases. 

b. In addition to the current requirements of 49 CFR § 229.27(a)(1), all filtering 

devices associated with the CCB brake system shall be cleaned, repaired, or replaced 

on a 368-calendar day interval. 

c. The brake pipe vent valve shall be inspected, cleaned, repaired, and tested every 

5 years. 

d. The air compressor shall be maintained to perform as intended with emphasis on 

detection of oil contamination of main reservoir air. 

e. FRA reserves the right to modify or rescind this waiver at any time, if failures or 

conditions warrant, or in the event of noncompliance with any of the conditions of 

this waiver. 
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B – 4 

CSX Transportation - CCB Test Waiver

Re: Docket Number FRA-1999-6252

CSX Transportation (CSX) was granted a test waiver to prove that the new technology incorporated 

in the CCB electronic brake system is more reliable and safer in the rail transportation industry with 

the intent of moving to a performance-based criterion with components replaced or repaired as 

required. The waiver is applicable to the New York Air Brake Corporation (NYAB) Computer 

Controlled Brake (CCB) System on CSX locomotives, per the conditions outlined below. The 

waiver also provides that a committee (Joint CSX/CCB Committee) be created that is comprised of 

representatives from: 

1. FRA 

2. CSX 

3. Brotherhood of Locomotive Engineers 

4. International Association of Machinists and Aerospace Workers 

5. NYAB, A Knorr Brake Company 

6. General Electric Transportation Systems–Locomotive Division 

7. Electro Motive Division (EMD) 

8. GE Harris Railway Electronics 

9. Rockwell Transportation Electronics 

10. Harmon Industries 

11. Any other organization or manufacturer involved with the CCB brake system used on 

locomotives under the test plan. 

The waiver is subject to the following conditions: 

1. The Joint CSX/CCB Committee is responsible for adopting and establishing a test plan 

which shall prescribe all testing parameters. 

2. All testing procedures and parameters are subject to approval of the FRA test monitor, who 

shall be appointed by FRA’s Associate Administrator for Railroad Safety/Chief Safety 

Officer. 

3. An opportunity to witness all inspections and tests, which are part of the test plan, will be 

afforded each member of the Joint CSX/CCB Committee. Each member of the Joint 

CSX/CCB committee shall be provided advance notice of such inspections and tests. 

4. CSX will provide FRA and the Joint CSX/CCB Committee with a monthly report of all 

reported brake failures on all locomotives under the test plan. 
Motive Power and Equipment Compliance Manual 

B – 5

5. The FRA test monitor retains the right to modify or suspend any test performed under the 

test plan. 

6. A periodic (92-day) test of the CCB brake system shall be conducted as required by 

49 CFR § 229.23, to include a complete functionality test of the locomotive brake system. 

7. All brake system filtering devices and dirt collectors shall be replaced annually. 

8. FRA reserves the right to modify or rescind this waiver at any time upon receipt of 

information pertaining to the safety of rail operations or in the event of noncompliance with 

any of the conditions of this waiver. 

Amtrak Electronic Brake Equipment, used on HHP8 Electric Locomotives

Re: Docket Number FRA-2001-10596

The National Railroad Passenger Corporation (Amtrak) was granted a waiver, FRA 2001-10596, of 

compliance from certain provisions of the Railroad Power Brake and Drawbars regulations, 49 

CFR Part 229, regarding the required periodic tests of locomotive brake equipment. This waiver is 

specific to the electronic brake equipment manufactured by Knorr–New York Air Brake Company 

(NYAB) and used on Amtrak’s HHP8 electric locomotives. It extends the time interval from 2 

years to 5 years on the NYAB electronic brake equipment used on the HHP8 electric locomotives 

owned by Amtrak with the following conditions: 

1. Amtrak shall furnish FRA a list of all locomotives equipped with this type of electronic 

brake equipment to include: the locomotive reporting marks, the date that each locomotive 

entered service, and a quarterly update of locomotives that are placed in service with this 

brake. 

2. Amtrak must submit to FRA a quarterly report listing air brake failures, both pneumatic and 

electrical, of all locomotives under this waiver to include: type and date of failure, 

locomotive reporting marks, and the cause and resolution of the problem. 

3. All verified failures of pneumatic components must be promptly reported to FRA prior to 

disassembly so that FRA personnel can witness disassembly of the failed component to 

determine the cause. 

4. Amtrak and FRA shall select one locomotive each calendar year for full functional testing, 

along with the disassembly and inspection of the pneumatic valves. If any pneumatic valve 

fails the functional test on the locomotive, the failure shall be verified on a test rack or on 

another locomotive. If the failure is verified, another locomotive will be selected for full 

functional testing and teardown inspection. If there are no failures, nothing further will be 

required for that calendar year. 

5. FRA reserves the right to increase the number of locomotives tested, as the total number of 
Federal Railroad Administration 

B – 6 

locomotives subject to this waiver increases. 

6. All systems for the discharge or removal of moisture, such as automatic drain valves and air 

dryers, shall be serviced and maintained to function as intended by the manufacturer. 

7. In addition to the current requirements of 49 CFR § 229.27(a)(1), all filtering devices 

associated with the brake system shall be cleaned, repaired, or replaced on a 

368-calendar day interval. 

8. The brake pipe vent valve shall be inspected, cleaned, repaired, and tested at a minimum of 

every 368 calendar days. 

9. The air compressor shall be maintained to perform as intended with an emphasis on 

detection of oil contamination of main reservoir air. 

10. Amtrak shall ensure that the correct waiver information is entered on Form F 6180-49A of 

each locomotive under this waiver. 

11. FRA reserves the right to modify or rescind this waiver at any time, if failures or conditions 

warrant, or in the event of noncompliance with any of the conditions of this waiver. Also, at 

the conclusion of the 5-year period, FRA reserves the right to extend the waiver if 

conditions warrant. 

Locomotive Brakes

Association of American Railroads - 26-L Type Brake – 1,104 days to 48 Months

Re: Docket Number FRA-2005-21325

The Association of American Railroads (AAR) was granted a waiver to extend the time interval 

requirements of 49 CFR § 229.27, Annual Tests, and 49 CFR § 229.29, Biennial Tests, for all 

locomotives equipped with 26-L type brake systems and air dryers. This waiver applies to any 

locomotive equipped with a 26-L type brake system and a functioning air dryer, irrespective of 

ownership or the trackage on which the locomotive is operating. The new time interval is 

1,472 calendar days for air brake equipment subject to the clean, repair, and test requirements of 49 

CFR §§ 229.27(a)(2) and 229.29(a), with the following conditions: 

1. The waiver shall apply only to locomotives equipped with 26-L type brake equipment and a 

functioning air dryer. 

2. Any locomotive operating under this waiver shall have the waiver properly noted on Form 

FRA F 6180-49A. 

3. All air brake filtering devices shall be cleaned or replaced annually. 

4. All systems for the discharge or removal of moisture, such as automatic drain valves and air 
Motive Power and Equipment Compliance Manual 

B – 7

dryers shall be maintained to function as intended. 

5. The air compressor must be maintained to perform as intended with emphasis on detection 

of oil contamination of the main reservoir air. 

6. FRA and AAR shall work together and randomly select two locomotives, annually, for a 

teardown inspection of the brake equipment, to be witnessed by FRA and invited labor 

representatives. The number and frequency of this condition may be changed by FRA based 

on the performance of the brake equipment or the results of the inspections. 

Locomotive Recordkeeping

The Government Paperwork Elimination Act (GPEA), Public Law No. 105-277, requires executive 

agencies to provide “for the option of the electronic maintenance, submission, or disclosure of 

information, when practicable as a substitute for paper” and “for the use and acceptance of 

electronic signatures, when practicable.” 

Through the waiver process, many railroads have opted to take advantage of the GPEA regarding 

the paper requirements found in certain provisions of 49 CFR Part 229, Railroad Locomotive Safety 

Standards. Specifically, the calendar day inspection records and the periodic inspection information 

required for the locomotive “Blue Card,” Form FRA F6180.49A. 

Daily Inspection Electronic Recordkeeping

The following are waivers that allow for the use of electronic signatures and electronic storage of 

daily locomotive inspection records for specific railroads. 

Burlington Northern Santa Fe Railway BNSF 

Re: Docket Number FRA-2000-7782 

1. The daily inspection record maintained on board the locomotive will be amended to include 

a place for the person performing the inspection to sign, and a place to indicate if the 

locomotive was found in noncompliance at the time of the daily inspection. 

2. All transportation employees performing daily locomotive inspections will use a secure and 

unique electronic access code, assigned to them for logging on and off duty and reporting 

“Hours of Service,” for reporting daily locomotive inspection into the database. 

3. Locomotives found defective during the daily inspection will have the block checked on the 

onboard record that indicates a defective condition; a noncomplying tag will be made; the 

defective condition reported to the Network Operations Center Mechanical Desk for 

disposition; and the locomotive will not be used until corrective action is taken. 

4. The operations desk will enter the information into the database and will determine how best 
Federal Railroad Administration 

B – 8 

to handle the defective locomotive: set out, send a mechanic, or move as a noncomplying 

locomotive. 

5. Crewmembers using the quick tieup provision (Hours of Service) will not be polled on 

locomotive inspection and review defects entered by operations center. 

6. Mechanical department employees performing daily inspections will be required to fill out 

the onboard record and will be provided a secure and unique electronic access code for 

reporting inspections, listing repairs made, or providing additional information to the 

existing records within the database. 

7. Database records will be maintained for 92 days. Records of repairs made will be added to 

the database without any change to the original reported information. Database access will 

be provided through the use of employee ID’s and a unique password. 

8. BNSF will protect and prevent tampering with the database by use of a security program. 

At this time, BNSF uses an IBM program called Resource Access Control Facility (RACF) 

which allows the user to append the record but not alter the original records. BNSF shall 

use RACF or an equivalent level of protection to protect database information. 

9. FRA inspectors will be provided all electronic records for specific locomotives (upon 

request) from BNSF at any computer terminal accessing the program, i.e., transportation and 

mechanical facilities. BNSF is responsible for maintaining onboard records and database 

records of daily inspections. 

10. FRA reserves the right to modify or rescind the waiver upon receipt of information 

pertaining to the safety of rail operations, evidence of electronic database integrity 

deficiencies, or in the event of noncompliance with any condition of this waiver. 

Union Pacific Railway (UP)

Re: Docket Number FRA-2001-11014 

1. The daily inspection record maintained onboard the locomotive will be amended to 

include a place for the person performing the inspection to sign or provide their 

employee identification number, and a place to indicate if the locomotive was found in

noncompliance at the time of the daily inspection.

2. All transportation employees performing daily locomotive inspections will use a secure 

and unique electronic access code assigned to them for logging on and off duty, and

reporting hours of service (HOS) for reporting daily locomotive inspections into the

database.

3. Locomotives found with FRA non-complying conditions during a daily inspection will

have the block on the onboard record indicating a defective condition checked. Unless 

the person performing the inspection can correct the condition, a record of the repairs 

must be made. If the condition cannot be corrected, a non-complying tag must be made, 
Motive Power and Equipment Compliance Manual 

B – 9

the defective condition reported electronically, and the locomotive will not be used until

corrective action is taken. If the non-complying locomotive is moved from the point at

which the condition was discovered, then it must be moved in compliance with 49 CFR

Section 229.9, Movement of non-complying locomotives, and must be reported to the 

Harriman Dispatch Center (HDC) prior to movement.

4. The HDC mechanical desk will enter the information into the database and determine 

how best to handle the non-complying locomotive (i.e., to set out, send a mechanic, or 

move as a non-complying locomotive). The crewmember will report the locomotive 

inspection at tie-up, if HOS does not apply. 

5. Crewmembers using the quick tie-up provision will not be polled on locomotive

inspection or review of the defects entered by the operations center.

6. Mechanical department employees performing daily inspections will be required to 

fill out the onboard record and will be provided with a secure and unique electronic 

access code for reporting inspections, listing repairs, or providing additional 

information to the existing records within the database.

7. Database records will be maintained for 92 days. Records of repairs will be made to 

the database without any change to the original reported information. Database access

will be secured and the employees inputting the data will be identified.

8. UP will 1) protect and prevent tampering with the database by the use of a security 

program, 2) allow the user to append the records but not alter the original records, and 3) 

use an electronic security program to protect database information.

9. FRA inspectors will be provided all electronic records for specific locomotives (upon 

request from UP at any locomotive mechanical facility) and these records must also be

made available, upon request, at local transportation department facilities. UP is 

responsible for maintaining onboard records and database records of daily inspections.

10. This waiver expires 5 years from the date of this letter. At the conclusion of the 5-year 

period, FRA reserves the right to extend the waiver if conditions warrant and UP has 

made a written request for an extension to FRA's Office of Safety Assurance and 

Compliance at least 6 months prior to the expiration date. 

FRA reserves the right to modify or rescind this waiver at any time upon receipt of information 

pertaining to the safety of rail operations, evidence of electronic database integrity deficiencies, 

or in the event of noncompliance with any of the conditions of this waiver.

Norfolk Southern Corporation (NS)

Re: Docket Number FRA-2005-22822
Federal Railroad Administration 

B – 10 

1. The daily inspection record maintained onboard the locomotive will be amended to include 

a place for the person performing the inspection to sign or provide their employee 

identification number, and a place to indicate if the locomotive was found in noncompliance 

at the time of the daily inspection. 

2. All transportation employees performing daily locomotive inspections will use a secure and 

unique electronic access code, assigned to them for logging on and off duty and reporting 

“Hours of Service,” for reporting daily locomotive inspection into the database. 

3. Locomotives found defective during the daily inspection will be reported to the Mechanical 

Operations Center (MOC) for disposition. 

4. The MOC will enter the information into the database and will determine how best to handle 

the defective locomotive; set out, send a mechanic, or move as a noncomplying locomotive. 

5. Crewmembers using the quick tieup provision (Hours of Service) will not be polled on 

locomotive inspection and review defects entered by MOC. 

6. Mechanical department employees performing daily inspections will be required to fill-out 

the onboard record and will be provided a secure and unique electronic access code for 

reporting inspections, listing repairs made, or providing additional information to the 

existing records within the database. 

7. Database records will be maintained for 92 days. Records of repairs made will be added to 

the database by the person performing the repair and without any change to the original 

reported information. Database access will be provided through the use of employee IDs 

and a unique password. 

8. NS will protect and prevent tampering with the database by use of a security program to 

protect database information. 

9. FRA inspectors will be provided all electronic records for specific locomotives upon request 

from NS at any mechanical department computer terminal. 

10. NS is responsible for maintaining onboard records and database records of daily inspections. 

11. This waiver shall be identified in block number 19 of the Form FRA F6180.49A 

(locomotive blue card) and explanatory information regarding the scope and content of the 

waiver shall be included under “Remarks.” 

12. FRA reserves the right to modify or rescind the waiver upon receipt of information 

pertaining to the safety of rail operations, evidence of electronic database integrity 

deficiencies, or in the event of noncompliance with any condition of this waiver. 

Electronic Recordkeeping–Form FRA F6180.49A (Blue Card)Burlington Northern Santa Fe 

Railway (BNSF)
Motive Power and Equipment Compliance Manual 

B – 11

Re: Docket Number FRA-2003-16440 (See similar conditions below) 

Canadian National Railway (CN)

Re: Docket Number FRA-2004-18960 (See similar conditions below) Limited to 

locomotives owned or leased by CN, Grand Trunk Western Railroad(GTW), Duluth, 

Winnipeg& Pacific Railway (DWP), Wisconsin Central LTD (WC), Bessemer and Lake Erie 

Railroad (BL&E), Duluth, Missabe and Iron Range Railway (DM&IR), and British Columbia 

Railway (BC) maintained by those railroads in their facilities.) 

Union Pacific Railway (UP)

Re: Docket Number FRA-2004-17308 (See similar conditions below)

The above railroads have been granted waivers from certain provisions of 49 CFR Part 229, 

Railroad Locomotive Safety Standards, which permit the railroads to maintain and store 

electronically, the periodic inspection information required for the Blue Card (Form FRA 

F6180.49A). Employees who perform periodic, annual, and biannual inspections are permitted to 

record the inspection information electronically. These waivers also allow the railroad to store the 

information in an electronic database. Locomotives will still be required to have either a Form 

FRA F6180.49A or a computer-generated form in place on the locomotive. The following 

conditions apply to these waivers: 

1. The railroads are authorized to use a computer-generated form instead of a standard Form 

FRA F6180.49A. This form must contain all the required information, including identifying 

this waiver. The printed name of the person performing inspections will satisfy the 

requirement for a signature. 

2. The railroad will maintain an electronic database to identify those units that require periodic 

inspection before continuing in service. 

3. Employees and supervisors required to make entries on Form FRA F6180.49A will be 

provided with a secure and unique electronic access code for reporting and certifying 

inspections and repair records. 

4. The railroads will provide employees inspection packages, including all required tests and 

procedures needed to perform required inspection and tests. If provided electronically, a 

means for the person performing inspections to indicate completion shall be provided by an 

assigned unique electronic access code. 

5. Inspection packages will include defects and repairs made to the locomotive over the 

previous 92 days. 

6. FRA inspectors will be provided computer-generated copies of Form FRA F6180.49A upon 

request at any of the railroads’ locomotive facilities using the electronic reporting covered 

by this waiver. 

Electronically Controlled Pneumatic (ECP) Brake Requirements for BNSF and NS
Federal Railroad Administration 

B – 12 

Re: Docket Number FRA-2006-26435

A waiver was granted to BNSF and NS in order to begin equipping and operating pilot trains using 

ECP brakes instead of conventional pneumatic brake systems, subject to the following conditions: 

1. This waiver shall apply only to BNSF and NS trains equipped and operating with ECP brake 

systems. 

2. The ECP brake system shall, at a minimum, meet all of the current AAR standards 

contained in the AAR Manual of Standards and Recommended Practices related to ECP 

brake systems. 

3. A train operating in ECP brake mode shall receive a Class I brake test (as described in 

49 CFR § 232.205(c)) by a qualified mechanical inspector (QMI), and shall receive a predeparture freight car inspection (pursuant to the requirements specified in 49 CFR 

Part 215) by an inspector designated under 49 CFR § 215.11 at the initial terminal where the 

train is originally assembled or where a unit or cycle train Class I brake test is required. 

4. Trains operating in ECP brake mode shall not operate at a distance that exceeds its 

destination or 3,500 miles, whichever is less, without receiving another Class I brake 

inspection and another Part 215 inspection, as outlined in Condition 3. 

5. A unit or cycle train operating in ECP brake mode shall receive a Class I brake inspection 

and Part 215 inspection at least every 3,500 miles, as outlined in Condition 3. 

6. The distance that any car in a train has traveled since receiving a Class I brake test by a QMI 

will determine the distance that the train has traveled. 

7. A train operating in ECP brake mode shall receive a Class I brake test as described in 

§ 232.205(c) by a qualified person at a location where the train is off air for a period of more 

than 24 hours. 

8. Each car equipped with an ECP brake system that is added to a train operating in ECP brake 

mode shall receive a Class I brake test as described in 49 CFR § 232.205(c) by a qualified 

person, unless all of the following are met: 

a. The car has received a Class I brake test by a QMI within the last 3,500 miles. 

b. Information identified in 49 CFR § 232.205(e) relating to the performance of the 

previous Class I brake test is provided to the train crew. 

c. The car has not been off air for more than 24 hours. 

d. A visual inspection of the car’s brake systems is conducted to ensure that the brake 

equipment is intact and properly secured. This may be accomplished as part of the 

inspection required under 49 CFR § 215.13 and may be conducted while the car is 

off air. 
Motive Power and Equipment Compliance Manual 

B – 13

9. An ECP brake-equipped train that receives a Class I brake test by a QMI is not required to 

receive any Class IA brake tests. 

10. A train operating in ECP brake mode shall receive a Class III brake test as described in 

49 CFR §§ 232.211(b), (c), and (d), at the location where the configuration of the train is 

changed or whenever the continuity of the brake pipe or electrical connection is broken or 

interrupted, with the train consist otherwise remaining unchanged. 

11. In lieu of the specific brake pipe service reductions required throughout 49 CFR Part 232, an 

electronic signal that provides an equivalent application and release of the brakes shall be 

used when conducting any required inspection or test on a freight car or train operating in 

the ECP brake mode. 

12. In lieu of the specific piston travel ranges specified throughout 49 CFR 232, the piston 

travel on freight cars equipped with ECP brake systems shall be within the piston travel 

limits stenciled or marked on the car or badge plate consistent with the manufacturers’ 

recommended limits. However, at no time shall piston travel on a standard 12-inch 

stroke piston exceed 9 inches when conducting a Class I brake inspection as outlined in 

Condition 3. 

13. When conducting the Class I brake test as outlined in Condition 3, the composition type 

brake shoe must have at least 2-inch thickness, including the lining and backing plate. 

14. A freight car or a freight train shall be exempted from the requirements contained in 

49 CFR §§ 232.205(a) and (b), 232.207, 232.209, 232.211(a), and 232.505 when it is 

equipped with an ECP brake system and operating in ECP brake mode. 

15. Handling of defective equipment with ECP brake systems. 

a. Ninety-five percent of the cars in an ECP brake-equipped train operating in ECP 

brake mode shall be effective and operative prior to use or departure from the train’s 

initial terminal or any location where a Class I brake test is required to be performed 

on the entire train by a QMI. 

b. A freight car or locomotive equipped with an ECP brake system that is found with 

inoperative or ineffective brakes for the first time during the performance of a Class 

I brake test or while en route, may be used or hauled without civil penalty liability 

under this part to its destination (not to exceed 3,500 miles); provided all applicable 

provisions of this section are met and the defective car or locomotive is hauled in a 

train operating in ECP brake mode. 

c. A freight car equipped with an ECP brake system that is known to have arrived 

with ineffective or inoperative brakes at the location of a train’s initial terminal or at 

a location where a unit or cycle train Class I brake test is required, shall not depart 

that location with ineffective or inoperative brakes in a train operating in ECP brake 
Federal Railroad Administration 

B – 14 

mode unless the location does not have the ability to conduct the necessary repairs. 

If the location does not have the ability to conduct the necessary repairs, the car must 

be properly tagged in accordance with 49 CFR 

§ 232.15(b), and can only be hauled for the purpose of repair to the nearest forward 

location where the necessary repairs can be performed. 

d. A train operating in ECP brake mode shall not operate with less than 85 percent 

of the cars in the train with operative brakes, unless it is operating in switch mode 

for the purpose of moving to the nearest forward location where necessary repairs or 

changes to the consist can be made. 

e. A freight car equipped with an ECP brake system that is part of a train operating 

in ECP brake mode that is found with a defective non-brake safety appliance may be 

used or hauled without civil penalty to the nearest forward location where the 

necessary repairs can be performed consistent with the guidance contained in 

49 CFR § 232.15(f). 

f. A train operating with conventional pneumatic brakes shall not operate with 

freight cars equipped with standalone ECP brake systems, unless the train has 100-

percent effective and operative brakes on all cars equipped with conventional 

pneumatic brakes and at least 95-percent effective and operative brakes when 

including the freight cars equipped with standalone ECP brake systems; or when cars 

are picked up en route, there shall be a minimum of 85-percent operative brakes for 

the entire train when including the standalone ECP brake-equipped cars. 

16. A freight car equipped with an ECP brake system that is found with ineffective or 

inoperative brakes will be considered electronically tagged under 49 CFR 

§§ 232.15(b)(1) and (b)(5), if the car is used or hauled in a train operating in ECP brake 

mode and the ECP brake system is able to display the location and identification of the car 

with defective brakes. The railroad shall develop a method acceptable to FRA to capture 

and secure the appropriate information so that it is accessible to FRA and appropriate 

railroad mechanical personnel, as well as satisfy the requirements of 49 CFR § 232.15(b)(3). 

17. Each railroad shall submit to FRA’s Associate Administrator for Railroad Safety/Chief 

Safety Officer a list of locations on its system, and an updated list of locations where ECP 

brake system repairs will be performed each time a location is added or subtracted to its 

system. 

18. In addition to the maintenance requirements contained in 49 CFR §§ 232.303(b) through 

(d), a freight car equipped with an ECP brake system shall be inspected before being 

released from a shop or repair track to ensure the proper and safe condition of the following: 

a. ECP brake system wiring and brackets. 

b. ECP brake system electrical connections. 

c. Electrical grounds and impedance. 
Motive Power and Equipment Compliance Manual 

B – 15

d. Car mounted ECP brake system components. 

19. Using procedures developed by the brake manufacturer, a single car air brake test shall be 

performed on a freight car equipped with an ECP brake system before being placed into 

revenue service for the first time using the ECP brake system. 

20. Trains operating in ECP brake mode are exempt from the two-way end-of-train device 

requirements contained in Subpart E of 49 CFR Part 232. 

21. Prior to operating a freight train in ECP brake mode, the ECP brake system’s end-of-train 

(ECP-EOT) device must be connected to the brake pipe and trainline cable at the end of the 

train operating with an ECP brake system. The ECP-EOT must be connected to the 

network and must be transmitting status messages to the head end unit (HEU) before the 

trainline power can be energized continuously. The ECP-EOT shall continually report 

brake pipe pressure and trainline voltage to the HEU. 

22. Each railroad shall develop and implement a training program for personnel that operate or 

perform inspection, testing, or maintenance on a freight car and/or freight train equipped 

with an ECP brake system. The training shall meet all of the requirements 

specified in 49 CFR §§ 232.203(a), (b), (e), and (f), and 49 CFR Part 240. 

23. Each railroad shall amend its operating rules to govern safe train handling procedures 

related to ECP brake systems and equipment under all operating conditions, which shall be 

tailored to the specific equipment and territory of the railroad. 

24. Prior to operating a train under authority of this waiver, the railroads shall provide notice to 

the FRA in the same manner provided for extended haul trains pursuant to 49 CFR 

§ 232.213(a)(1). 

25. This waiver is effective for a 5-year period from the date of this letter or until a final rule is 

implemented for trains equipped with ECP brake systems. At the conclusion of the 

5-year period, FRA reserves the right to extend the waiver if conditions warrant and 

BNSF/NS make a written request for an extension to FRA’s Office of Safety Assurance and 

Compliance within 6 months of the expiration date. 

Blue Signal

Two-way end-of-train (EOT) telemetry devices–Removal and replacement of batteries by train and 

yard crewmembers, and utility employees for BNSF

Re: Docket Number FRA-2001-10660

BNSF was granted relief from certain provisions of 49 CFR Part 218, Railroad Operating 

Practices, regarding blue signal protection of workers. Specifically, the waiver permits train and 

yard crewmembers and utility employees, to remove and replace batteries in two-way EOT 

telemetry devices while the EOT is in place on the rear of the train for which the individual has 
Federal Railroad Administration 

B – 16 

been assigned; without establishing any blue signal protection. Waiver FRA 2001-10660 has been 

reissued on April 5, 2007, with the following conditions: 

1. This approval applies only to BNSF train and yard crewmembers and utility employees. 

2. Battery change-outs can be performed on EOT devices by train and yard crewmembers and 

utility employees only on railroad rolling equipment that they have been called to operate 

(or been assigned to as “utility employees”). 

3. If the function of changing out the EOT device batteries requires the use of tools, then 

establishing blue signal protection specified by 49 CFR Part 218 is required. 

4. BNSF shall immediately report any accident involving this procedure to the FRA Office of 

Safety Assurance and Compliance. 

5. This waiver extension is effective for a period of 5 years from the date of this letter. FRA 

may extend the waiver if conditions warrant and BNSF provides the FRA Office of Safety 

Assurance and Compliance with a written request for an extension within 

6 months of the expiration date. 

6. FRA reserves the right to modify or rescind this waiver upon receipt of information 

pertaining to the safety of rail operations or in the event of noncompliance with the 

conditions specified. 

Two-Way End-of-Train Device (EOT)

TrainLink II ATX end-of-train telemetry (TrainLink II) with power supplied by an Air Generator

Re: Docket Number FRA-2001-9270 

Wabtec Railway Electronics (Wabtec) was granted relief from the requirements of 49 CFR § 

232.407(f)(2), which requires: 

The rear unit batteries shall be sufficiently charged at the initial terminal or 

other point where the device is installed and throughout the train’s trip to 

ensure that the end-of-train-device will remain operative until the train 

reaches its destination. 

The waiver provides relief from certain provisions of Title 49 Code of Federal Regulations (CFR) 

Part 232, Brake System Safety Standards for Freight and Other Non-Passenger Trains and 

Equipment, regarding End-of-Train Devices. Specifically, the waiver provides conditional relief 

from Section 232.407(f)(2), which requires that the rear unit batteries be sufficiently charged at 

the initial terminal or other point where the device is installed and throughout the train's trip to 

ensure that the end-of-train-device will remain operative until the train reaches its destination.
Motive Power and Equipment Compliance Manual 

B – 17

Based on the satisfactory performance of the TrainLink II- ATX end-of-train telemetry unit, 

(TrainLink II), FRA hereby extends the waiver subject to the same conditions as the original 

waiver as follows:

1. This waiver only applies to the TrainLink II - ATX end-of-train telemetry unit, 

(TrainLink II) manufactured by Wabtec;

2. Railroads using these devices shall ensure that all personnel (including contractors) 

responsible for the application, removal, testing, maintenance, and/or operation of the 

TrainLink II, shall be adequately trained to perform the applicable job functions;

3. The TrainLink II shall be installed and operating with power supplied by the air generator 

during the performance of all required air brake inspections and tests on trains equipped 

with this device;

4. When a TrainLink II is used to replace an existing end-of-train-device on a train, an air brake 

leakage test shall be satisfactorily performed on the train with the 

TrainLink II operating and powered by the air generator; 

5. If there is any indication that the backup battery is dead or has a low charge condition at 

the time of installation, the device shall be considered defective and can not be used until 

the battery is changed or fully charged; 

6. Railroads using the TrainLink II shall perform recommended maintenance 

according to Wabtec's procedures, specifications, and time intervals with particular 

emphasis on the air filter; 

 

7. The device shall meet or exceed all Association of American Railroads (AAR) standards 

and specifications regarding the two-way end-of-train device and shall be compatible with 

other devices that meet the AAR standards and specifications; 

8. The TrainLink II device battery shall provide a minimum of 12 hours of continuous 

power to operate the device in the event the air generator stops functioning; 

9. With the exception of Section 232.403(g)(2), use of TrainLink II devices remain subject 

to the provisions of 49 CFR Part 232, including but not limited to:

a. all inspection, testing, operating, and training requirements specified in 49 

CFR Part 232; and

b. all en route failure restrictions specified in 49 CFR Part 232; 

10. Wabtec shall provide FRA with an annual report summarizing the performance of the 

product and any recurring or catastrophic problems associated with the device. The report 

shall also include any modifications to the product, as well as the number of units provided 

to the railroads; 
Federal Railroad Administration 

B – 18 

11. Wabtec shall provide a copy of this approval letter to each railroad supplied with the 

TrainLink II device. Use of this equipment by any railroad is not permitted until such 

railroad provides to FRA's Associate Administrator for Safety a written confirmation that 

the railroad agrees to abide by the conditions established in this letter; and 

12. This waiver is effective for a 5-year period from the date of this letter. At the 

conclusion of the 5-year period, FRA reserves the right to extend the waiver if 

conditions warrant and Wabtec has made a written request for an extension to FRA's 

Office of Safety Assurance and Compliance, within 6 months of the expiration date. 

Re: Docket Number FRA-2006-25794 

FRA conditionally approved Quantum's petition for relief from the requirements of 49 CPR 

232.403(g)(2), subject to the conditions listed below: 

l. This waiver applies only to EOT devices manufactured by Quantum and described in the 

"Design Review Verification/Validation" section of Quantum's August 15, 2006, waiver 

petition document. Quantum EOT devices installed in the railroad operating environment 

shall be of the same type and model of components used in the samples tested and 

referenced in Quantum's August 15, 2006, waiver petition document. 

2. Railroads utilizing Quantum EOT devices shall ensure that all personnel (including 

contractors) responsible for installing, removing, testing, maintaining, and using the devices, 

are adequately trained in the operation of the device. 

3. Quantum EOT devices shall be installed and operating, with power supplied by the airdriven alternator, during the performance of all required air brake inspections and tests of 

trains equipped with this device. 

4. If at the time of installation, there is any indication that the batteries are dead or have a low 

charge condition, the Quantum EOT device shall be considered defective and may not be 

used until corrective action is taken (e.g. the batteries are charged or replaced). 

5. Quantum EOT devices shall meet or exceed all Association of American Railroad (AAR) 

EOT device communication standards. 

6. Each Quantum EOT device equipped with two batteries shall provide a minimum of 12 

hours of continuous power to operate the device in the event the air-driven alternator stops 

functioning. 

7. With the exception of 49 CFR 232.403(g)(2), Quantum EOT devices remain subject to all 

other provisions of 49 CPR Part 232, including, but not limited to: 

a. All inspection, testing, operating, and training requirements specified in 49 CFR Part 232 

and Part 221; and 

b. All en route failure restrictions specified in 49 CFR Part 232 and Part 221. 
Motive Power and Equipment Compliance Manual 

B – 19

8. Quantum shall provide FRA with an annual report summarizing the performance of its EOT 

devices equipped with the type of batteries described in the petition. The report shall include 

the number of units provided to railroads, modifications made to the devices, and any 

recurring or catastrophic problems associated with the devices. 

9. FRA reserves the right to independently test any Quantum EOT device and to withdraw the 

approval of this waiver at any time if its performance in the railroad operating environment 

fails to substantiate the submitted test results. 

10. The waiver is effective for a period of 5 years from the date of this letter. FRA may extend 

the waiver if favorable conditions warrant, and if Quantum submits a written request for an 

extension. Such request for an extension should be filed with FRA's, Office of Safety 

Assurance and Compliance at least 6 months prior to the expiration date of this waiver. 

11. FRA reserves the right to modify or rescind this waiver upon receipt of information 

pertaining to the safety of railroad operations or in the event of noncompliance with the 

conditions specified. · 

Addendum to Waiver FRA-2006-25794:

FRA and state inspectors are advised that Quantum Engineering, Inc., is presently part of Invensys, 

Inc., and that devices waived under FRA-2006-25794 may appear with either Quantum or Invensys 

identification labels. 

TrainLink II - Calibration Requirements for Units Equipped with the Wabtec Railway Electronics 

(WRE) Digitally Synthesized Radio 

Re: Docket Number FRA-2004-18895 

Wabtec Railway Electronics (Wabtec) was granted relief from the requirements of 49 CFR § 

232.407(f)(2), which requires 

the telemetry equipment to be tested for accuracy and calibrated, if necessary, at least every 

368 days; and requires that the date and location of the last calibration or test, as well as the name 

of the person performing the calibration or test, be legibly displayed on a weather-resistant sticker 

or other marking device affixed to the outside of both the front and the rear unit.

FRA reviewed the petition and conditionally approved the request, with the following conditions: 

1. This waiver applies only to Wabtec TrainLink II Head of Train Devices (HTD) and EOTs 

that were produced since March 4, 2002, and all existing TrainLink units that have been 

upgraded with the new WRE digitally synthesized radio. 

2. A weather-resistant sticker shall be attached to each unit, identifying that the unit is 

equipped with the new WRE digital radio and is covered by this waiver. Wabtec shall 

control the application of these stickers to the units and ensure that the stickers are not 

arbitrarily distributed to the railroads for railroad employees to apply to the units. 

3. Wabtec shall immediately provide written notification to FRA’s Office of Safety Assurance 
Federal Railroad Administration 

B – 20 

and Compliance of any unusual occurrences with the performance of these devices. 

American Short Line Regional Railroad Association (ASLRRA) - Restrictions on Heavy Grade 

Operation Without Two-Way EOT

Re: Docket Number PB-97-12

Based on ASLRRA’s request for reconsideration, the results of additional analyses and data 

furnished by Volpe, and in consideration of economic impacts on small entities, the FRA Railroad 

Safety Board conditionally approved petition PB-97-12 to permit trains to operate in heavy grade 

territories without a two-way EOT, only under the following restrictions and conditions: 

1. Only railroads that have fewer than 400,000 annual employee work hours qualify for this 

waiver. 

2. This waiver is limited to trains operating with a maximum of 200 trailing tons per 

locomotive axle. [trailing tons means the total tonnage (cars and lading) behind all 

locomotives providing power]. 

3. Each locomotive axle used to calculate the trailing tonnage shall have an operative air brake. 

4. Each railroad desiring to operate under the terms of this waiver shall provide written 

notification to the Director, Office of Safety Assurance and Compliance. The notification 

shall include the maximum grade and specific location(s) where relief is requested. A 

written description of the operating rules for the proposed operation shall also be included. 

The railroad may proceed upon acknowledgment by the Director of receipt of notification. 

5. Any train operation over a section of track with an average grade greater than 4 percent shall 

be equipped with a functional two-way EOT device. 

6. The values in the following table shall be used for the purposes of this waiver only. The 

allowable trailing tons per locomotive axle are determined by the speed and the percentage 

of grade. Neither the speed nor the grade can exceed the allowable trailing tonnage per 

locomotive axle. The percentage of grade is the average from the top of the mountain to the 

base of the mountain. Speeds listed in the table are maximum speeds allowed for grade and 

trailing tonnage combinations. However, railroads should set the speed limit in accordance 

with operating conditions at the location for which the waiver is applied, with particular 

attention to avoiding the 10–25 mile per hour range on jointed-track that may cause or 

accentuate harmonic roll of loaded cars. 

ASLRRA Waiver PB-97-12 - Relief From Two-Way End-of-Train Requirements

Trailing tons per 

locomotive axle 

10 mph 15 mph 20 mph 25 mph 

up to 75 4.0 percent grade 4.0 percent grade 4.0 percent grade 4.0 percent grade 

76–100 3.5 percent grade 3.5 percent grade 3.5 percent grade 3.5 percent grade 

101–125 3.0 percent grade 3.0 percent grade 3.0 percent grade 2.5 percent grade 
Motive Power and Equipment Compliance Manual 

B – 21

126–150 2.5 percent grade 2.5 percent grade 2.5 percent grade 2.5 percent grade 

151–175 2.0 percent grade 2.0 percent grade 2.0 percent grade 2.0 percent grade 

176–200 

maximum 

2.0 percent grade 2.0 percent grade 2.0 percent grade 1.0 percent grade 

7. If the train is equipped with dynamic brakes, the engineer shall determine the condition of 

the dynamic brakes prior to descending a grade, and such brakes shall be used to supplement 

the braking effort as required to control the train. 

8. Grade/curvature and other local conditions may require the setting of retainers as specified 

by individual railroad operating rules. 

9. If there is an incident where trainline blockage or loss of train brakes occurs, the wheels and 

brake system of the locomotives and cars shall be inspected after the train is safely brought 

to a complete stop, and a report made immediately to the FRA regional office. 

10. The conditions of this waiver apply to all operations applicable to two-way EOT operations. 

11. FRA reserves the right to deny a railroad inclusion to this waiver if conditions so justify. 

12. FRA reserves the right to modify or rescind this waiver (as to all or individual railroads) at 

any time upon receipt of information pertaining to the safety of rail operations or in the 

event of noncompliance with any of the conditions of this waiver. 

Passenger Equipment Safety Standards

Passenger Brakes

Re: Docket Number FRA-2003-15340

The American Association of Private Railroad Car Owners, Inc. (AAPRCO) was granted a 

conditional waiver from 49 CFR § 238.231(m)(2), which specifies that: 

Up to two cars may be operated in direct release mode when the rest of the 

cars in the train are operated in graduated release mode, provided that the 

cars operated in direct release mode are hauled at the rear of the train 

consist. 

This waiver modifies the requirements to read as, “Up to two cars may be operated in direct release 

mode when the rest of the cars in the train are operated in graduated release mode.” thereby, 

eliminating the placement restrictions of the direct release cars to the rear of the train. 

This waiver applies to passenger train operations that are subject to 49 CFR Part 238, with the 

following conditions: 

1. The maximum number of cars that may be operated in direct release mode, when the rest of 
Federal Railroad Administration 

B – 22 

the cars in the train are operated in graduated release mode, is two. 

2. The hauling railroad is responsible for the safe placement of these cars in the trains, to 

include the right of refusal. 

3. The locomotive engineer shall be notified in writing of the location of these cars in the train, 

along with any operating restrictions. 

4. The hauling railroad is responsible for providing the locomotive engineer with adequate 

training on operating trains in graduated-release mode that include cars operating in the 

direct-release mode. 

Highway Rail Vehicles such as RoadRailer7, RailRunner7, Etc.

An approved waiver is required for the operation of this type of equipment because the equipment 

does not comply with 49 CFR Part 231, which specifies the number, location, and dimensional 

specifications for handholds, ladders, sill steps, uncoupling levers, and hand brakes; and 49 CFR § 

232.2, which regulates drawbar height. The following waivers have been granted to specific 

railroads: 

Burlington Northern Santa Fe Railway Company - (BNSF)

Re: Docket Number FRA-1999-5895

Standard RoadRailer7 Operations

1. This approval applies only to BNSF RoadRailer equipment operation. 

2. Interchange will only be permitted with a railroad that has a comparable approval to operate 

RoadRailer equipment. 

3. RoadRailer units shall only be operated in trains consisting exclusively of RoadRailer units 

and locomotives, unless conditions shown below are complied with. 

4. Trains consisting exclusively of RoadRailer equipment shall be limited to a maximum 

trailing tonnage of 4,800 tons (equivalent to 125 Mark V RoadRailer units or 200 

PupRailers). 

5. At no time shall the train length exceed the equivalent of 125 Mark V RoadRailer units. 

6. An adapter unit (CouplerMate bogie) must be used between the hauling locomotive and the 

first RoadRailer unit in the train; the first RoadRailer behind the adapter unit must not be 

empty. 

7. Each adapter unit (CouplerMate bogie) shall be equipped with a toolbox containing 

appropriate instructions, job aids, and the necessary tools and equipment required to address 
Motive Power and Equipment Compliance Manual 

B – 23

problems that may be encountered en route by the train crew. 

8. Trains will only be permitted to pickup or set-out RoadRailer units at locations specifically 

designed to perform these functions with mechanical personnel that are trained and on duty 

for the purpose of assembly and disassembly of RoadRailer units, unless a defective 

condition develops en route that would require a RoadRailer unit to be set out of the train. 

9. Hazardous materials are permitted to be hauled in RoadRailer units provided: (1) the 

particular commodities are limited to those listed in Table 2 of 49 CFR § 172.504; (2) the 

shipment complies with other relevant provisions of the hazardous materials regulations; (3) 

placarding provisions of 49 CFR Subpart F of Part 172 shall apply during rail movements; 

and (4) cargo tanks, multi-unit tank car tanks, portable tanks, and intermodal (IM) portable 

tanks handling hazardous materials are not permitted in this service. 

10. Each RoadRailer adapter unit (CouplerMate bogie) that does not have safety appliances that 

are compliant with current Federal regulations (with the exception of the hand brake), must 

be stenciled on each side, in clearly legible letters not less then 6 inches high, “NO SAFETY 

APPLIANCES” and “DO NOT RIDE,” at a location that is visible to a person walking at 

track level beside the unit. 

11. BNSF shall have instructions that prohibit anyone from riding RoadRailer equipment, unless 

it is an adapter unit (CouplerMate7 bogie) specifically designed to be ridden and is not 

stenciled as required in Condition 10. Strict enforcement of this rule is required. 

12. New terminal facilities for RoadRailer equipment shall, to the extent feasible, be designed to 

limit the frequency and length of reverse movements. Reverse movements of RoadRailer 

equipment, with personnel riding CouplerMates equipped with compliant safety appliances, 

shall not exceed 10 mph. 

13. Whenever a shoving move of RoadRailer equipment is required, the movement shall be 

protected by either an individual riding an adapter unit (CouplerMate bogie) specifically 

designed to be ridden; or by an individual walking with the movement, and the speed of the 

move shall not exceed that of the individual walking. 

14. Maximum speed of a RoadRailer train is 60 mph, unless: (1) the RoadRailer units are 

equipped with AAR-1B narrow flange profile (1:40 taper) and maintained in that condition, 

whereby the maximum speed shall be 70 mph; or (2) the entire consist is made up of 

ReeferRailer units, whereby the maximum speed shall be 70 mph. In addition, BNSF shall 

consider the recommendations cited in FRA’s safety analysis of October 18, 2000 (page 9), 

and in FRA form of actions taken. 

15. Piston travel at initial terminal shall be 11⁄4–31⁄2 inches. 

16. The air brake shall be considered ineffective at 3e inches. 

17. BNSF shall ensure that all personnel (including contractors) responsible for assembly, 
Federal Railroad Administration 

B – 24 

inspection, testing, maintenance, and operation of RoadRailer equipment have been trained 

and qualified to perform those duties prior to undertaking them, including the instructions in 

the approval pertinent to their duties. Training for railroad operating and mechanical 

personnel who may encounter the equipment, shall specifically include training necessary to 

provide for their personal safety when working on or in proximity to the equipment. 

Supervisors shall also possess the knowledge and skills required of employees subject to 

their direct supervision. Effective coincident with compliance dates established for 

revisions to 49 CFR Part 232 (see 66 FR 4101; January 17, 2001), all personnel required to 

receive training subject to this approval shall have their qualifications for duties (related to 

RoadRailer equipment) documented in the same manner provided in that part. 

18. BNSF shall maintain adequate records to demonstrate the current qualification status of all 

personnel assigned to operate, inspect, test, and maintain RoadRailer equipment. 

19. BNSF supervisors or their representatives shall exercise oversight to ensure that all tasks 

and maintenance/repair practices are performed in accordance with the railroad’s written 

procedures, applicable Standards and Recommended Practices of the AAR, current AAR 

Interchange Rules, and all applicable Federal regulatory requirements. 

20. BNSF shall immediately report any accident involving this equipment to FRA’s Office of 

Safety Assurance and Compliance in Washington, DC. 

21. FRA reserves the right to modify or rescind this waiver at any time upon receipt of 

information pertaining to the safety of rail operations or in the event of noncompliance with 

any of the conditions of this waiver. 

RoadRailer7 Mixed Train Operations

All the approvals for Standard RoadRailer Operations (items 1–21 above) will apply for mixed train 

consists, except as follows: 

22. For the purpose of this approval, a “mixed train” shall consist of a solid block of 

RoadRailers coupled to the rear of conventional freight equipment, including multi-platform 

intermodal, autorack cars, and other freight cars meeting Association of American Railroads 

standards for interchange service.1

23. RoadRailer equipment must be placed in a solid block at the rear of a mixed train. 

RoadRailer equipment must be placed behind any manned helper locomotives. Remote or 

manned locomotives (DPU units) may be placed immediately ahead of RoadRailer 

equipment or further up in the train towards the front. 

24. Train makeup rules must be published in the BNSF=s current timetable and other special 

 

1

 The term “mixed train” is used in lieu of the term “commingled trains” which was used in BNSF’s petition. 
Motive Power and Equipment Compliance Manual 

B – 25

instructions. BNSF=s computer-based information system must also be modified to flag 

noncompliant train makeup combinations and assure that information is furnished to 

applicable train crews before train departure. BNSF System Train Makeup Instructions and 

Subdivision Train Makeup Instructions also apply to mixed trains with RoadRailer 

equipment. When these instructions specify trailing tonnage limits, RoadRailer tonnage will 

be included. Train makeup instructions for trains with remote distributive power unit (DPU) 

or manned helper locomotives will also be included. 

25. RoadRailer equipment totaling more than 3,000 tons must not be coupled to an empty long 

car (80 feet or longer and excluding multi-platform cars) or an empty TTOX car (single 

platform, single axle, BNSF Car Code QA) or a TTFX car with any empty 

platform (four platform, single axle, BNSF Car Code QDE). The BNSF computer-based 

Train Profile indicates 80-foot or longer cars in the train with the letter “L.” 

26. The following is a general approval for mixed train operations: Freight trains containing a 

maximum of 80 cars by car count that have less than 5 cars equipped with EOC cushioning, 

may be placed ahead of RoadRailer equipment provided the entire train does not exceed a 

total length of 7,500 feet including locomotives, and the RoadRailer equipment does not 

exceed a maximum of 1,000 tons. The BNSF Train Profile indicates EOC cushion equipped 

cars in the train with the letter “E.” 

27. The following is a specific approval for intermodal trains which primarily contain multiplatform doublestack/spine equipment which have very little slack. For intermodal trains 

containing doublestack and spine equipment with less than 5 other cars equipped with EOC 

cushioning, any combination of this equipment may be placed ahead of RoadRailer 

equipment, provided the entire train does not exceed a total length of 8,500 feet including 

locomotives and RoadRailer equipment does not exceed a maximum of 3,500 tons. Any 

RoadRailer weighing less than 28 tons must be placed in the rear 1,500 tons of the train. 

Doublestack equipment may include multi-platform articulated (BNSF Car Kind Codes QY, 

QV) and solid drawbar equipment (codes QW, QX, QT) and stand alone single platform 

equipment (code QU). Spine cars are multi-platform articulated equipment (codes QC, QO, 

Q5, QE, QM). This exception does not apply to westbound and eastbound trains on the 

Raton and Glorieta Subdivisions. 

28. The following is a specific approval for trains with primarily EOC cushioned equipment 

(such as autorack and trailer on flatcar (TOFC)/container on flatcar (COFC) trains). For 

intermodal trains containing five or more cars equipped with EOC cushioning, any total 

combination of all cars in the train up to a maximum of 40 cars by car count may be placed 

ahead of RoadRailers provided the entire train does not exceed a total length of 5,500 feet 

including locomotives, and RoadRailer equipment does not exceed a maximum of 500 tons. 

Twin flats (BNSF Car Kind Codes QB, QD, QL) are considered two of these types of cars. 

RoadRailers must not be placed behind more than a total of 

40 cars equipped with EOC cushioning, such as autorack and/or TOFC/COFC cars due to 

the potential slack action with EOC equipment. 

29. BNSF must provide an annual written report to FRA’s Office of Safety Assurance and 
Federal Railroad Administration 

B – 26 

Compliance concerning the mixed train operations which identifies any incident, equipment 

modifications, operational difficulties, and/or any related failed equipment. 

30. Under the program of training set forth in Condition 17 above, BNSF’s operating and 

mechanical personnel must receive explicit training on RoadRailer mixed train makeup 

instructions pertinent to this waiver. 

Canadian National Illinois Central Railroad (CN/IC)

Re: Docket Number FRA-2000-8089

1. This waiver applies only to CN/IC RoadRailer7 equipment operation. 

2. Interchange will only be permitted with a railroad that has a comparable waiver to operate 

RoadRailer equipment. 

3. RoadRailer equipment shall not be commingled with conventional railroad rolling 

equipment. RoadRailer units shall only be operated in trains consisting exclusively of 

RoadRailer units and locomotives. 

4. RoadRailer Trains shall be limited to a maximum trailing tonnage of 4,800 tons (equivalent 

to 125 Mark V RoadRailer units or 200 PupRailers). 

5. At no time shall the train length exceed the equivalent of 125 Mark V RoadRailer units. 

6. An adapter unit (CouplerMate bogie) must be used between the hauling locomotive and the 

first RoadRailer unit in the train. 

7. Each adapter unit (CouplerMate bogie) shall be equipped with a toolbox containing 

appropriate instructions, job aids, and the necessary tools and equipment required to address 

problems that may be encountered en route by the train crew. 

8. Trains will only be permitted to pickup or set-out RoadRailer units at locations specifically 

designed to perform these functions with mechanical personnel that are trained and on duty 

for the purpose of assembly and disassembly of RoadRailer units, unless a defective 

condition develops en route that would require a RoadRailer unit to be set out of the train. 

9. Hazardous materials are permitted to be hauled in RoadRailer units, provided: (1) the 

particular commodities are limited to those listed in Table 2 of 49 CFR § 172.504; (2) the 

shipment complies with other relevant provisions of the hazardous materials regulations; (3) 

placarding provisions of 49 CFR Subpart F of Part 172 shall apply during rail movements; 

and (4) cargo tanks, multi-unit tank car tanks, portable tanks, and intermodal (IM) portable 

tanks handling hazardous materials are not permitted in this service. 

10. Each RoadRailer adapter unit (CouplerMate bogie) that does not have safety appliances that 

are compliant with current Federal regulations (with the exception of the hand brake), must 
Motive Power and Equipment Compliance Manual 

B – 27

be stenciled on each side, in clearly legible letters not less than 6 inches high, “NO SAFETY 

APPLIANCES” and “DO NOT RIDE,” at a location that is visible to a person walking at 

track level beside the unit. 

11. CN/IC shall have instructions that prohibit anyone from riding RoadRailer equipment, 

unless it is an adapter unit (CouplerMate bogie) specifically designed to be ridden and is not 

stenciled as required in Condition 10. Strict enforcement of this rule is required. 

12. New terminal facilities for RoadRailer equipment shall, to the extent feasible, be designed to 

limit the frequency and length of reverse movements. Reverse movements of RoadRailer 

equipment, with personnel riding CouplerMates equipped with compliant safety appliances, 

shall not exceed 10 mph. 

13. Whenever a shoving move of RoadRailer equipment is required, the movement shall be 

protected by either an individual riding an adapter unit (CouplerMate bogie) specifically 

designed to be ridden; or by an individual walking with the movement, and the speed of the 

move shall not exceed that of the individual walking. 

14. Maximum speed of a RoadRailer train is 60 mph, unless the RoadRailer units are equipped 

with AAR-1B narrow flange profile (1:40 taper) and maintained in that condition, whereby 

the maximum speed shall be 70 mph. 

15. Piston travel at initial terminal shall be 11⁄4–31⁄2 inches. 

16. The air brake shall be considered ineffective at 3e inches. 

17. CN/IC shall ensure that all personnel (including contractors) responsible for assembly, 

inspection, testing, maintenance, and operation of RoadRailer equipment have been trained 

and qualified to perform those duties prior to undertaking them, including instruction in the 

provisions of this waiver pertinent to their duties. Training for railroad operating and 

mechanical personnel who may encounter the equipment, shall specifically include training 

necessary to provide for their personal safety when working on or in proximity to the 

equipment. Supervisors shall also possess the knowledge and skills required of employees 

subject to their direct supervision. Effective coincident with compliance dates established 

for revisions to 49 CFR Part 232 (see 66 FR 4101; 

January 17, 2001), all personnel required to receive training subject to this condition shall 

have their qualifications for duties (related to RoadRailer equipment) documented in the 

same manner provided in that part. 

18. CN/IC shall maintain adequate records to demonstrate the current qualification status of all 

personnel assigned to operate, inspect, test, and maintain RoadRailer equipment. 

19. CN/IC supervisors or their representatives shall exercise oversight to ensure that all tasks 

and maintenance/repair practices are performed in accordance with the railroad’s written 
Federal Railroad Administration 

B – 28 

procedures, applicable Standards and Recommended Practices of the AAR, current AAR 

Interchange Rules and all applicable Federal regulatory requirements. 

20. CN/IC shall immediately report any accident involving this equipment to FRA’s Office of 

Safety Assurance and Compliance in Washington, DC. 

21. FRA reserves the right to modify or rescind this waiver at any time upon receipt of 

information pertaining to the safety of rail operations or in the event of noncompliance with 

any of the conditions of this waiver. 

Norfolk Southern Corporation - (NS)

Re: Docket Number FRA-2002-11896

1. This approval applies only to NS RoadRailer7 equipment operation. 

2. Interchange will only be permitted with a railroad that has a comparable waiver to operate 

RoadRailer equipment. 

3. RoadRailer equipment shall not be commingled with conventional railroad rolling 

equipment. RoadRailer units shall only be operated in trains consisting exclusively of 

RoadRailer units and locomotives. 

4. RoadRailer trains shall be limited to a maximum trailing tonnage as specified in the 

following tables. 

Table 1 B Allowable Total Trailing Tonnage Behind RoadRailers Weighing 

28 Tons or More for Various Curve-Compensated Grades and Maximum Curvature

Curvature 2 4 6 8 10 

Grade 

+/-2.2 5200 5200 5200 5100 4400 

+/-2.1 5200 5200 5200 5200 4600 

+/-2.0 5200 5200 5200 5200 4800 

+/-1.9 5200 5200 5200 5200 5100 

Note: All grades less than +/-1.9 are 5,200 trailing tons 

Table 2 B Allowable Total Trailing Tonnage Behind RoadRailers Weighing 

18–27 Tons for Various Curve-Compensated Grades and Maximum Curvature

Curvature 2 4 6 8 10 

Grade 
Motive Power and Equipment Compliance Manual 

B – 29

+/-2.2 5200 4600 4000 3300 3000 

+/-2.1 5200 4800 4200 3500 3100 

+/-2.0 5200 5000 4400 3600 3300 

+/-1.9 5200 5200 4600 3800 3400 

+/-1.8 5200 5200 4900 4000 3600 

+/-1.7 5200 5200 5200 4300 3800 

+/-1.6 5200 5200 5200 4600 4100 

+/-1.5 5200 5200 5200 4900 4400 

+/-1.4 5200 5200 5200 5200 4700 

+/-1.3 5200 5200 5200 5200 5000 

Note: All grades less than +/-1.3 are 5,200 trailing tons 

Table 3 B Allowable Total Trailing Tonnage Behind RoadRailers WeighingLess than 

18 Tons (Essentially Empty) for Various Curve Compensated Grades and Maximum 

Curvature

Curvature 2 4 6 8 10 

Grade 

+/-2.2 4300 3700 3000 2600 2400 

+/-2.1 4500 3900 3100 2800 2500 

+/-2.0 4800 4100 3300 2900 2600 

+/-1.9 5000 4300 3400 3000 2700 

+/-1.8 5200 4500 3600 3200 2900 

+/-1.7 5200 4800 3800 3400 3100 

+/-1.6 5200 5100 4100 3600 3300 

+/-1.5 5200 5200 4400 3900 3500 

+/-1.4 5200 5200 4700 4200 3700 

+/-1.3 5200 5200 5000 4500 4000 

+/-1.2 5200 5200 5200 4900 4400 

+/-1.1 5200 5200 5200 5200 4800 
Federal Railroad Administration 

B – 30 

Note: All grades less than +/-1.1 are 5,200 trailing tons 

5. At no time shall the train length exceed the equivalent of 150 Mark V RoadRailer7 units. 

6. An adapter unit (CouplerMate bogie) must be used between the hauling locomotive and the 

first RoadRailer7 unit in the train. The first RoadRailer7 unit that is placed on the 

CouplerMate bogie must be loaded to a minimum of 28 tons (total weight of lading, trailer 

empty weight, and first intermediate bogie) whenever the weight of the train exceeds 1,500 

trailing tons. 

7. Each adapter unit (CouplerMate bogie) shall be equipped with a toolbox containing 

appropriate instructions, job aids, and the necessary tools and equipment required to address 

problems that may be encountered en route by the train crew. 

8. Trains will only be permitted to pickup or set-out RoadRailer7 units at locations specifically 

designed to perform these functions with mechanical personnel that are trained and on duty 

for the purpose of assembly and disassembly of RoadRailer7 units, unless a defective 

condition develops en route that would require a RoadRailer unit to be set out of the train. 

9. Hazardous materials are permitted to be hauled in RoadRailer7 units provided: (1) the 

particular commodities are limited to those listed in Table 2 of 49 CFR § 172.504; (2) the 

shipment complies with other relevant provisions of the hazardous materials regulations; (3) 

placarding provisions of 49 CFR Subpart F of Part 172 shall apply during rail movements; 

and (4) cargo tanks, multi-unit tank car tanks, portable tanks, and intermodal (IM) portable 

tanks handling hazardous materials are not permitted in this service. 

10. Each RoadRailer7 adapter unit (CouplerMate bogie) that does not have safety appliances 

that are compliant with current Federal regulations (with the exception of the hand brake), 

must be stenciled on each side, in clearly legible letters not less than 6 inches high, “NO 

SAFETY APPLIANCES” and “DO NOT RIDE,” at a location that is visible to a person 

walking at track level beside the unit. 

11. NS shall have instructions that prohibit anyone from riding RoadRailer7 equipment, unless 

it is an adapter unit (CouplerMate bogie) specifically designed to be ridden and is not 

stenciled as required in Condition 10. Strict enforcement of this rule is required. 

12. New terminal facilities for RoadRailer7 equipment shall, to the extent feasible, be designed 

to limit the frequency and length of reverse movements. Reverse movements of 

RoadRailer7 equipment, with personnel riding CouplerMates equipped with compliant 

safety appliances, shall not exceed 10 mph. 

13. Whenever a shoving move of RoadRailer7 equipment is required, the movement shall be 

protected by either an individual riding an adapter unit (CouplerMate bogie) specifically 

designed to be ridden; or by an individual walking with the movement, and the speed of the 

move shall not exceed that of the individual walking. 
Motive Power and Equipment Compliance Manual 

B – 31

14. Maximum speed of a RoadRailer7 train is 60 mph, unless the RoadRailer7 units are 

equipped with AAR-1B narrow flange profile (1:40 taper) and maintained in that condition, 

whereby the maximum speed shall be 70 mph. 

15. Piston travel at initial terminal shall be 11⁄4–31⁄2 inches. 

16. The air brake shall be considered ineffective at 3e inches. 

17. NS shall ensure that all personnel (including contractors) responsible for assembly, 

inspection, testing, maintenance, and operation of RoadRailer7 equipment have been trained 

and qualified to perform those duties prior to undertaking them, including instruction in the 

provisions of this waiver pertinent to their duties. Training for railroad operating and 

mechanical personnel who may encounter the equipment, shall specifically include training 

necessary to provide for their personal safety when working on or in proximity to the 

equipment. Supervisors shall also possess the knowledge and skills required of employees 

subject to their direct supervision. Effective coincident with compliance dates established 

for revisions to 49 CFR Part 232 (see 66 FR 4101; 

January 17, 2001), all personnel required to receive training subject to this condition shall 

have their qualifications for duties (related to RoadRailer equipment) documented in the 

same manner provided in that part. 

18. NS shall maintain adequate records to demonstrate the current qualification status of all 

personnel assigned to operate, inspect, test, and maintain RoadRailer7 equipment. 

19. NS supervisors or their representatives shall exercise oversight to ensure that all tasks and 

maintenance/repair practices are performed in accordance with the railroad’s written 

procedures, applicable Standards and Recommended Practices of the AAR, current AAR 

Interchange Rules, and all applicable Federal regulatory requirements. 

20. When planned train makeup is determined for a train scheduled to operate over a given 

corridor, a “manifest” of planned units specifying number and order of units and their 

individual weights is generated. 

21. Using the manifest and working down from the planned head of the consist, identify and 

locate: 

a. Unit closest to the head of the train that is less than 18 tons. 

(1) After locating closest to the head of the train that is less than 18 tons, add up 

trailing tonnage on all following units. 

(2) Compare total trailing tonnage of these units to allowable trailing tonnage 

restrictions by corridor as specified in Table 3. 

(3) If total trailing tonnage is in excess of allowable limits, remove unit(s) that are 

less than 18 tons and recalculate until reaching acceptable tonnage restriction for 

corridor or reduce trailing tonnage from rear of train until corridor limit is 

reached. 
Federal Railroad Administration 

B – 32 

b. Unit closest to the head of the train that is 18–27 tons. 

(1) After locating closest to the head of the train that is 18–27 tons, add up trailing 

tonnage on all following units. 

(2) Compare total trailing tonnage of these units to allowable trailing tonnage 

restrictions by corridor as specified in Table 2. 

(3) If total trailing tonnage is in excess of allowable limits, remove unit(s) that are 

18–27 tons and recalculate until reaching acceptable restriction for corridor or 

reduce trailing tonnage from rear of train until corridor limit is reached. 

c. Compare total trailing tonnage of planned train to Table 1 and ensure that total 

trailing tonnage is within limits for the corridor as specified in Table 1. 

22. Restrictive factors (i.e., trailing tonnage, etc.) shall be identified on the train consist. A hard 

copy of the train consist shall be provided to the train crew. 

23. Monitoring and Compliance. 

a. All departed train consists shall be monitored for compliance by Triple Crown and 

NS. 

b. Details of all departed consists and identified restrictive factors shall be maintained 

on hand at Triple Crown headquarters. 

c. Triple Crown shall pursue development of computer-generated edits and 

electronically stored consists detailing all restrictive factors regarding trailing 

tonnage. 

24. Within 60 days of the date of this letter, NS shall submit to FRA the following: 

a. Final bulletins/special instructions as published to Triple Crown and other personnel 

involved in the movements, including clear explanation of methods to be used to 

determine the weight of the trailers. 

b. Timetable for development and deployment of electronic system to monitor 

compliance/flag noncompliance with tonnage restrictions. 

25. NS shall immediately report any accident involving this equipment to FRA’s Office of 

Safety Assurance and Compliance in Washington, DC. 

26. FRA reserves the right to modify or rescind this waiver at any time upon receipt of 

information pertaining to the safety of rail operations or in the event of noncompliance with 

any of the conditions of this waiver. 

CSX Transportation - CSX
Motive Power and Equipment Compliance Manual 

B – 33

Re: Docket Number SA-87-4 and PB-87-5

1. This waiver applies only to CSX RoadRailer7 equipment operation. 

2. Interchange will only be permitted with a railroad that has a comparable waiver to operate 

RoadRailer equipment. 

3. RoadRailer equipment shall not be commingled with conventional railroad rolling 

equipment. RoadRailer units shall only be operated in trains consisting exclusively of 

RoadRailer units and locomotives. 

4. RoadRailer Trains shall be limited to a maximum trailing tonnage of 4,800 tons (equivalent 

to 125 Mark V RoadRailer7 units or 200 PupRailers). 

5. At no time shall the train length exceed the equivalent of 125 Mark V RoadRailer units. 

6. An adapter unit (CouplerMate bogie) must be used between the hauling locomotive and the 

first RoadRailer unit in the train. 

7. Each adapter unit (CouplerMate bogie) shall be equipped with a toolbox containing 

appropriate instructions, job aids, and the necessary tools and equipment required to address 

problems that may be encountered en route by the train crew. 

8. Trains will only be permitted to pickup or set-out RoadRailer units at locations specifically 

designed to perform these functions with mechanical personnel that are trained and on duty 

for the purpose of assembly and disassembly of RoadRailer units, unless a defective 

condition develops en route that would require a RoadRailer unit to be set out of the train. 

9. Hazardous materials are permitted to be hauled in RoadRailer units provided: (1) the 

particular commodities are limited to those listed in Table 2 of 49 CFR § 172.504; (2) the 

shipment complies with other relevant provisions of the hazardous materials regulations; (3) 

placarding provisions of 49 CFR Subpart F of Part 172 shall apply during rail movements; 

and (4) cargo tanks, multi-unit tank car tanks, portable tanks, and intermodal (IM) portable 

tanks handling hazardous materials are not permitted in this service. 

10. Each RoadRailer adapter unit (CouplerMate bogie) that does not have safety appliances that 

are compliant with current Federal regulations (with the exception of the hand brake), must 

be stenciled on each side, in clearly legible letters not less than 6 inches high, “NO SAFETY 

APPLIANCES” and “DO NOT RIDE,” at a location that is visible to a person walking at 

track level beside the unit. 

11. CSX shall have instructions that prohibit anyone from riding RoadRailer equipment, unless 

it is an adapter unit (CouplerMate bogie) specifically designed to be ridden and is not 

stenciled as required in Condition 10. Strict enforcement of this rule is required. 

12. New terminal facilities for RoadRailer equipment shall, to the extent feasible, be designed to 

limit the frequency and length of reverse movements. Reverse movements of RoadRailer 
Federal Railroad Administration 

B – 34 

equipment, with personnel riding CouplerMates equipped with compliant safety appliances, 

shall not exceed 10 mph. 

13. Whenever a shoving move of RoadRailer equipment is required, the movement shall be 

protected by either an individual riding an adapter unit (CouplerMate bogie) specifically 

designed to be ridden; or by an individual walking with the movement, and the speed of the 

move shall not exceed that of the individual walking. 

14. Maximum speed of a RoadRailer train is 60 mph, unless the RoadRailer units are equipped 

with AAR-1B narrow flange profile (1:40 taper), and maintained in that condition, whereby 

the maximum speed shall be 70 mph. 

15. Piston travel at initial terminal shall be 13–32 inches. 

16. The air brake shall be considered ineffective at 3e inches. 

17. CSX shall ensure that all personnel (including contractors) responsible for assembly, 

inspection, testing, maintenance, and operation of RoadRailer equipment have been trained 

and qualified to perform those duties prior to undertaking them, including instruction in the 

provisions of this waiver pertinent to their duties. Training for railroad operating and 

mechanical personnel who may encounter the equipment, shall specifically include training 

necessary to provide for their personal safety when working on or in proximity to the 

equipment. Supervisors shall also possess the knowledge and skills required of employees 

subject to their direct supervision. Effective coincident with compliance dates established 

for revisions to 49 CFR Part 232 (see 66 FR 4101; January 17, 2001), all personnel required 

to receive training subject to this condition shall have their qualifications for duties (related 

to RoadRailer equipment) documented in the same manner provided in that part. 

18. CSX shall maintain adequate records to demonstrate the current qualification status of all 

personnel assigned to operate, inspect, test, and maintain RoadRailer equipment. 

19. CSX supervisors or their representatives shall exercise oversight to ensure that all tasks and 

maintenance/repair practices are performed in accordance with the railroad’s written 

procedures, applicable Standards and Recommended Practices of the AAR, current AAR 

Interchange Rules, and all applicable Federal regulatory requirements. 

20. CSX shall immediately report any accident involving this equipment to FRA’s Office of 

Safety Assurance and Compliance in Washington, DC. 

21. FRA reserves the right to modify or rescind this waiver at any time upon receipt of 

information pertaining to the safety of rail operations or in the event of noncompliance with 

any of the conditions of this waiver. 

The Texas Mexican Railway Company (TM)

Re: Docket Number FRA-2000-7040
Motive Power and Equipment Compliance Manual 

B – 35

1. This waiver applies only to RoadRailer7 equipment operating on the TM Railroad. 

2. Interchange will only be permitted with a railroad that has a comparable waiver to operate 

RoadRailer equipment. 

3. RoadRailer equipment shall not be commingled with conventional railroad rolling 

equipment. RoadRailer units shall only be operated in trains consisting exclusively of 

RoadRailer units and locomotives. 

4. RoadRailer Trains shall be limited to a maximum trailing tonnage of 4,800 tons (equivalent 

to 125 Mark V RoadRailer units or 200 PupRailers). 

5. At no time shall the train length exceed the equivalent of 125 Mark V RoadRailer units. 

6. An adapter unit (CouplerMate bogie) must be used between the hauling locomotive and the 

first RoadRailer unit in the train. 

7. Each adapter unit (CouplerMate bogie) shall be equipped with a toolbox containing 

appropriate instruction booklets, operating manuals, job aids, spare parts and the necessary 

tools required to address problems that may be encountered en route. 

8. Trains will not be permitted to pickup or set-out units en route, unless a defective condition 

demands the removal of a unit. 

9. Hazardous materials are permitted to be hauled in RoadRailer units, provided: (1) the 

particular commodities are limited to those listed in Table 2 of 49 CFR §172.504; (2) the 

shipment complies with other relevant provisions of the hazardous materials regulations; (3) 

placarding provisions of 49 CFR Subpart F of Part 172 shall apply during rail movements; 

and (4) cargo tanks, multi-unit tank car tanks, portable tanks, and intermodal (IM) portable 

tanks handling hazardous materials are not permitted in this service. 

10. Each RoadRailer unit must be stenciled on each side, in clearly legible letters not less than 6 

inches high, “NO SAFETY APPLIANCES” and “DO NOT RIDE,” at a location that is 

visible to a person walking at track level beside the unit. 

11. TM shall have instructions that prohibit anyone from riding RoadRailer equipment, with 

strict enforcement of this rule. 

12. Terminal facilities used in connection with assembly and disassembly of RoadRailer® 

trains shall be designed so that it is not necessary to make reverse movements to enter or 

depart from those facilities. The only reverse movements of the units would be limited to 

those needed to accomplish actual coupling of the units and those required as a consequence 

of some emergency situation. 

13. Shoving RoadRailer equipment should be avoided whenever possible. However, if a 

shoving move is required, the movement shall be protected by an individual walking with 

the movement, and the speed of the move shall not exceed that of the individual walking. 
Federal Railroad Administration 

B – 36 

14. Maximum speed of a RoadRailer train shall not exceed 60 mph. 

15. Piston travel at initial terminal shall be 13–32 inches. 

16. The air brake shall be considered ineffective with a piston travel of 3e inches or more. 

17. TM shall provide adequate training for all operating and mechanical personnel responsible 

for operating the equipment and performing mechanical inspections, tests, and repairs. The 

training curriculum shall specifically address all applicable Federal regulatory requirements, 

as well as the railroad’s operating rules, en route failure procedures, and applicable 

maintenance standards established by the Association of American Railroads (AAR) 

Interchange Rules. The training shall also cover any active FRA Safety Advisories 

regarding RoadRailer Safety (SA-99-03 and SA-99-03A); National Highway Traffic Safety 

Administration (NHTSA Recall Number 00V-025 and 00V-344); Manufacturer’s Service 

Bulletins (Wabash National SB2000-01 thru SB2000-06); and any AAR Advisories that 

may be issued. The training shall consist of both classroom and hands-on instruction 

modules designed to impart the knowledge and skills necessary for the performance of the 

employee’s duties. Each individual shall pass a written or oral examination, along with a 

hands-on demonstration of knowledge and skills necessary for handling RoadRailer 

equipment. Supervisors shall also possess the knowledge and skills necessary in the 

operation and maintenance of RoadRailer equipment. 

18. TM shall maintain adequate records to demonstrate the current qualification status of all 

personnel assigned to operate, inspect, test, and maintain RoadRailer equipment. 

19. TM supervisors or their representatives shall exercise oversight to ensure that all tasks and 

maintenance/repair practices are performed in accordance with the railroad’s written 

procedures, applicable Standards and Recommended Practices of the AAR, current AAR 

Interchange Rules, and all applicable Federal regulatory requirements. 

20. TM shall immediately report any accident involving this equipment to FRA’s Office of 

Safety Assurance and Compliance in Washington, DC. 

21. FRA reserves the right to modify or rescind this waiver at any time upon receipt of 

information pertaining to the safety of rail operations or in the event of noncompliance with 

any of the conditions of this waiver. 

As clarification in light of comments in the docket of this proceeding, it is intended that the training 

requirements specified in Condition 17 shall include apprizing employees on how to avoid risk 

potentially associated with operating, inspecting, and repairing such equipment by 

(1) following appropriate procedures, (2) avoiding unnecessarily placing themselves under or 

between units, and (3) ensuring that equipment is properly secured when it is necessary to do so. 
Motive Power and Equipment Compliance Manual 

B – 37

Safety Appliances 

Norfolk Southern Corporation (NS)

Re: Docket Number FRA-2008-0029 

On August 29, 2008, the FRA Railroad Safety Board (Board) reviewed the petition, field 

investigation and technical staff findings and determined that granting the requested relief was in 

the public interest and consistent with railroad safety. Accordingly, the Board granted the requested 

relief, subject to the following conditions: 

1. This waiver applies to all NS-owned flatcars operated solely in rail train service within the 

NS rail system. 

2. The uncoupling levers may be removed from both ends of flatcars subject to this waiver, 

except cars at each end of a rail train consist must be equipped with an uncoupling lever at 

the end of the car to which other equipment may couple. At each location where an 

uncoupling lever is removed, a car shall have the appropriate Association of American 

Railroads (AAR) approved coupler blocked and pinned, and locked to prevent the coupler 

from unintentionally uncoupling. 

3. At each location where an uncoupling lever is removed, a car shall be stenciled with the 

words, “CONTACT MECHANICAL DEPARTMENT TO COUPLE/UNCOUPLE,” in 

letters of contrasting color to the car and at least 2 inches high. 

4. Uncoupling shall be performed under blue flag protection and only by designated 

mechanical personnel at maintenance or shop locations where such personnel can safely get 

between the equipment to unlock and unblock the coupler. Prior to uncoupling any car 

subject to this waiver, the uncoupling lever of that car shall be reattached. 

5. NS shall develop and implement appropriate procedures to ensure the safe coupling and 

uncoupling of cars (subject to this waiver) in accordance with the conditions set forth in this 

letter. Such procedures shall be published in the appropriate NS rules and instructions 

applicable to train crews, maintenance-of-way forces, and mechanical personnel. 

6. NS shall develop and implement appropriate maintenance procedures for mechanical forces 

to maintain the couplers on all cars subject to this waiver. A maintenance record pertaining 

to the maintenance of the couplers on all cars subject to this waiver shall be maintained by 

NS at mechanical force locations where records are maintained. Such records shall be made 

available for FRA review upon request. 

7. NS must report immediately to FRA’s Office of Safety Assurance and Compliance any 

accident/incident and/or injury attributable to the removal of the uncoupling levers on the 

cars subject to this waiver. 

8. NS shall notify FRA prior to any change of operation of any car subject to this waiver. 
Federal Railroad Administration 

B – 38 

9. This waiver expires 5 years from the date of this letter. At the conclusion of the 5-year 

period, FRA reserves the right to extend the waiver if conditions warrant and NS has made a 

written request for an extension to FRA’s Office of Safety Assurance and Compliance not 

less than 6 months prior to the expiration date. 

CSX Transportation – (CSX)

Re: Docket Number FRA-2008-0039 

CSX seeks to remove the uncoupling levers from this equipment when moving both loaded and 

empty cars in rail train service.2 

On August 29, 2008, the FRA Railroad Safety Board (Board) reviewed the petition, field 

investigation and technical staff findings and determined that granting the requested relief was in 

the public interest and consistent with railroad safety. Accordingly, the Board granted the requested 

relief, subject to the following conditions: 

1. This waiver applies to all CSX-owned flatcars operated solely in rail train service within the 

CSX rail system. 

2. The uncoupling levers may be removed from both ends of flatcars subject to this waiver, 

except cars at each end of a rail train consist must be equipped with an uncoupling lever at 

the end of the car to which other equipment may couple. At each location where an 

uncoupling lever is removed, a car shall have the appropriate Association of American 

Railroads (AAR) approved coupler blocked and pinned, and locked to prevent the coupler 

from unintentionally uncoupling. 

3. At each location where an uncoupling lever is removed, a car shall be stenciled with the 

words, “CONTACT MECHANICAL DEPARTMENT TO COUPLE/UNCOUPLE,” in 

letters of contrasting color to the car and at least 2 inches high. 

4. Uncoupling shall be performed under blue flag protection and only by designated 

mechanical personnel at maintenance or shop locations where such personnel can safely get 

between the equipment to unlock and unblock the coupler. Prior to uncoupling any car 

subject to this waiver, the uncoupling lever of that car shall be reattached. 

5. CSX shall develop and implement appropriate procedures to ensure the safe coupling and 

uncoupling of cars subject to this waiver in accordance with the conditions set forth in 

this letter. Such procedures shall be published in the appropriate CSX rules and instructions 

applicable to train crews, maintenance-of-way forces, and mechanical personnel. 

 

2

 In its petition, CSX states that since the removal of uncoupling levers “is acceptable on the loaded trains, it is our 

request to extend that acceptance to the empty trains as well since these cars remain in unit train service for rail service 

only.” FRA notes that other than as specifically provided below, the removal of uncoupling levers from any railroad 

freight car, whether loaded or empty, violates Federal law. 
Motive Power and Equipment Compliance Manual 

B – 39

6. CSX shall develop and implement appropriate maintenance procedures for mechanical 

forces to maintain the couplers on all cars subject to this waiver. A maintenance record 

pertaining to the maintenance of the couplers on all cars subject to this waiver shall be 

maintained by CSX at mechanical force locations where records are maintained. Such 

records shall be made available for FRA review upon request. 

7. CSX must report immediately to FRA’s Office of Safety Assurance and Compliance any 

accident/incident and/or injury attributable to the removal of the uncoupling levers on the 

cars subject to this waiver. 

8. CSX shall notify FRA prior to any change of operation of any car subject to this waiver. 

9. This waiver expires 5 years from the date of this letter. At the conclusion of the 5-year 

period, FRA reserves the right to extend the waiver if conditions warrant and CSX has made 

a written request for an extension to FRA’s Office of Safety Assurance and Compliance not 

less than 6 months prior to the expiration date. 

Twin Cities & Western Railroad Company – (TCWR)

Re: Docket Number FRA-2008-0154 

FRA’s Railroad Safety Board (Board) has carefully reviewed TCWR’s request, the results of FRA’s 

own field investigation, the findings of its technical personnel, and comments submitted to the 

docket, and finds that granting the requested relief is in the public interest and consistent with 

railroad safety. Accordingly, the Board is granting TCWR’s requested relief subject to the 

following conditions: 

1. This waiver applies only to RailMate equipment operated by TCWR. 

2. Interchange of RailMate equipment is permitted only with railroads that have comparable 

waivers to operate RailMate equipment. 

3. RailMate will operate at the end of mixed freight trains, including trailer-onflatcar/container-on-flatcar trains, or as a dedicated consist of RailMate units. 

4. RailMate will be limited to a maximum trailing tonnage of 1,875 tons (50 loaded units). 

The bidirectional transition car will be appropriately equipped with cushioning to limit 

drawbar forces equal to or less than the longitudinal design load. 

5. At no time shall the train length exceed 125 RailMate units. 

6. A bidirectional transition unit must be used between the hauling locomotive or the last 

freight car and the first RailMate unit in the train. 
Federal Railroad Administration 

B – 40 

7. Each bidirectional transition unit shall be equipped with a toolbox containing appropriate 

instructions, job aids, and necessary tools and equipment required to address problems that 

may be encountered en route by the train crew. 

8. Trains shall only be permitted to pickup or set out RailMate units at locations: (1) that are 

specifically designed to perform these functions, and (2) where there are mechanical 

personnel that are trained and on duty for the purpose of assembling and disassembling 

RailMate trains. This condition does not apply where a defective condition develops en 

route that would require a RailMate unit to be set out of a train. 

9. Hazardous materials are permitted to be hauled in RailMate trains provided: (1) the 

particular commodities are limited to those listed in Table 2 of 49 CFR § 172.504; (2) the 

shipment complies with other relevant provisions of the hazardous materials regulations; (3) 

placarding provisions of 49 CFR Part 172, Subpart F shall apply during rail movements; and 

(4) cargo tanks, multi-unit tank car tanks, portable tanks, and intermodal portable tanks 

containing hazardous materials are not permitted in this service. 

10. Each RailMate bogie that does not have safety appliances that are compliant with Federal 

regulations shall be stenciled on each side in clearly legible letters not less than 6 inches 

high, “NO SAFETY APPLIANCES” and “DO NOT RIDE,” at a location that is visible to a 

person walking at track level beside the unit. 

11. TCWR shall issue instructions prohibiting anyone from riding RailMate equipment, unless it 

is a bidirectional unit specifically designed to be ridden and it is not stenciled as required in 

Condition 10. Strict enforcement of this rule is required. 

12. New terminal facilities for RailMate equipment shall, to the extent feasible, be designed to 

limit the frequency and length of shove movements. Shove movements of RailMate 

equipment, with personnel riding a RailMate bidirectional transition unit equipped with 

compliant safety appliances shall not exceed 10 mph. 

13. Whenever a shoving move of RailMate equipment is required, the movement shall be 

protected by either: (1) an individual riding a RailMate bidirectional transition unit 

specifically designed to be ridden; or (2) an individual walking with the movement, with the 

speed of the move not to exceed that of the individual walking. 

14. Maximum speed of RailMate train is 60 mph. 

15. Piston travel at initial terminal shall be 2 +/- 1⁄4 inches. 

16. The air brake shall be considered ineffective at 31⁄4 inches of piston travel. 

17. TCWR shall ensure that all personnel (including contractors) responsible for assembly, 

inspection, maintenance, and operation of RailMate equipment have been trained and 

qualified to perform those duties prior to undertaking them, including instruction in the 

provisions of this waiver pertinent to their duties. Training for railroad operating and 
Motive Power and Equipment Compliance Manual 

B – 41

mechanical personnel who may encounter the equipment shall specifically include training 

necessary to provide for their personal safety (including Blue Flag Rule) when working on 

or in proximity to the equipment. Supervisors shall also possess the knowledge and skills 

required of employees subject to their direct supervision. All personnel required to receive 

training subject to this condition shall have their qualifications for duties (related to 

RailMate equipment) documented in the same manner provided for in 49 CFR Part 232. 

Signed and dated copies of all training provided to personnel in accordance with this 

condition shall be kept on file at each RailMate operating terminal. 

18. TCWR shall maintain adequate records to demonstrate the current qualification status of all 

personnel assigned to operate, inspect, test, and maintain RailMate equipment. 

19. TCWR supervisors or their representatives shall exercise oversight to ensure that all tasks 

and maintenance/repair practices are performed in accordance with the railroad’s written 

procedures, applicable standards, and recommended practices of the Association of 

American Railroads (AAR) interchange rules, and all applicable Federal regulatory 

requirements. 

20. TCWR shall immediately report equipment and/or component failures and any accident, 

incident, or injury involving RailMate equipment to FRA’s Office of Safety Assurance and 

Compliance in Washington, DC. 

Escanaba & Lake Superior Railroad Company – (ELS)

Re: Docket Number FRA-2008-0155 

FRA’s Railroad Safety Board (Board) has carefully reviewed ELS’s request, the results of FRA’s 

own field investigation, the findings of its technical personnel, and comments submitted to the 

docket, and finds that granting the requested relief is in the public interest and consistent with 

railroad safety. Accordingly, the Board is granting ELS’s requested relief subject to the following 

conditions: 

1. This waiver applies only to RailMate equipment operated by ELS. 

2. Interchange of RailMate equipment is permitted only with railroads that have comparable 

waivers to operate RailMate equipment. 

3. RailMate will operate at the end of mixed freight trains, including trailer-onflatcar/container-on-flatcar trains, or as a dedicated consist of RailMate units. 

4. RailMate will be limited to a maximum trailing tonnage of 1,875 tons (50 loaded units). 

The bidirectional transition unit will be appropriately equipped with cushioning to limit 

drawbar forces equal to or less than the longitudinal design load. 

5. At no time shall the train length exceed the equivalent of 125 RailMate units. 
Federal Railroad Administration 

B – 42 

6. A bidirectional transition unit must be used between the hauling locomotive or the last 

freight car and the first RailMate unit in the train. 

7. Each bidirectional transition unit shall be equipped with a toolbox containing appropriate 

instructions, job aids, and necessary tools and equipment required to address problems that 

may be encountered en route by the train crew. 

8. Trains shall only be permitted to pickup or set out RailMate units at locations: (1) that are 

specifically designed to perform these functions, and (2) where there are mechanical 

personnel that are trained and on duty for the purpose of assembling and disassembling 

RailMate trains. This condition does not apply where a defective condition develops en 

route that would require a RailMate unit to be set out of a train. 

9. Hazardous materials are permitted to be hauled in RailMate trains provided: (1) the 

particular commodities are limited to those listed in Table 2 of 49 CFR § 172.504; (2) the 

shipment complies with other relevant provisions of the hazardous materials regulations; (3) 

during rail movements, the shipment shall comply with the placarding provisions of 49 CFR 

Part 172, Subpart F; and (4) cargo tanks, multi-unit tank car tanks, portable tanks, and 

intermodal portable tanks containing hazardous materials are not permitted in this service. 

10. Each RailMate bogie that does not have safety appliances that are compliant with Federal 

regulations shall be stenciled on each side, in clearly legible letters not less than 6 inches 

high, “NO SAFETY APPLIANCES” and “DO NOT RIDE,” at a location that is visible to a 

person walking at track level beside the unit. 

11. ELS shall issue instructions prohibiting anyone from riding RailMate equipment, unless it is 

a bidirectional unit specifically designed to be ridden and it is not stenciled as required in 

Condition10. Strict enforcement of this rule is required. 

12. New terminal facilities for RailMate equipment shall, to the extent feasible, be designed to 

limit the frequency and length of shove movements. Shove movements of RailMate 

equipment, with personnel riding a RailMate bidirectional transition unit equipped with 

compliant safety appliances, shall not exceed 10 mph. 

13. Whenever a shoving move of RailMate equipment is required, the movement shall be 

protected by either: (1) an individual riding a RailMate bidirectional transition unit 

specifically designed to be ridden; or (2) an individual walking with the movement, with the 

speed of the move not to exceed that of the individual walking. 

14. Maximum speed of RailMate train is 60 mph. 

15. Piston travel at initial terminal shall be 2 +/- 1⁄4 inches. 

16. The air brake shall be considered ineffective at 31⁄4 inches of piston travel. 
Motive Power and Equipment Compliance Manual 

B – 43

17. ELS shall ensure that all personnel (including contractors) responsible for assembly, 

inspection, maintenance, and operation of RailMate equipment have been trained and 

qualified to perform those duties prior to undertaking them, including instruction in the 

provisions of this waiver pertinent to their duties. Training for railroad operating and 

mechanical personnel who may encounter the equipment shall specifically include training 

necessary to provide for their personal safety (including Blue Flag Rule) when working on 

or in proximity to the equipment. Supervisors shall also possess the knowledge and skills 

required of employees subject to their direct supervision. All personnel required to receive 

training subject to this condition shall have their qualifications for duties related to RailMate 

equipment documented in the same manner provided for in 49 CFR Part 232. Signed and 

dated copies of all training provided to personnel in accordance with this condition shall be 

kept on file at each RailMate operating terminal. 

18. ELS shall maintain adequate records to demonstrate the current qualification status of all 

personnel assigned to operate, inspect, test, and maintain RailMate equipment. 

19. ELS supervisors or their representatives shall exercise oversight to ensure that all tasks and 

maintenance/repair practices are performed in accordance with the railroad’s written 

procedures, applicable standards, and recommended practices of the Association of 

American Railroads (AAR) interchange rules, and all applicable Federal regulatory 

requirements. 

20. ELS shall immediately report equipment and/or component failures and any accident, 

incident, or injury involving RailMate equipment to FRA’s Office of Safety Assurance and 

Compliance in Washington, DC. 

Canadian Pacific Railway – (CP)

Re: Docket Number FRA-2008-0163 

FRA’s Railroad Safety Board (Board) has carefully reviewed CP’s request, the results of FRA’s 

own field investigation, the findings of its technical personnel, and comments submitted to the 

docket, and finds that granting the requested relief is in the public interest and consistent with 

railroad safety. Accordingly, the Board is granting CP’s requested relief subject to the following 

conditions: 

1. This waiver applies only to RailMate equipment operated by CP. 

2. Interchange of RailMate equipment is permitted only with railroads that have comparable 

waivers to operate RailMate equipment. 

3. RailMate will operate at the end of mixed freight trains, including trailer-onflatcar/container-on-flatcar trains, or as a dedicated consist of RailMate units. 
Federal Railroad Administration 

B – 44 

4. RailMate will be limited to a maximum trailing tonnage of 1,875 tons (50 loaded units). 

The bidirectional transition car will be appropriately equipped with cushioning to limit 

drawbar forces equal to or less than the longitudinal design load. 

5. At no time shall the train length exceed 125 RailMate units. 

6. A bidirectional transition unit must be used between the hauling locomotive or the last 

freight car and the first RailMate unit in the train. 

7. Each bidirectional transition unit shall be equipped with a toolbox containing appropriate 

instructions, job aids, and necessary tools and equipment required to address problems that 

may be encountered en route by the train crew. 

8. Trains shall only be permitted to pickup or set out RailMate units at locations: (1) that are 

specifically designed to perform these functions, and (2) where there are mechanical 

personnel that are trained and on duty for the purpose of assembling and disassembling 

RailMate trains. This condition does not apply where a defective condition develops en 

route that would require a RailMate unit to be set out of a train. 

9. Hazardous materials are permitted to be hauled in RailMate trains provided: (1) the 

particular commodities are limited to those listed in Table 2 of 49 CFR § 172.504; (2) the 

shipment complies with other relevant provisions of the hazardous materials regulations; (3) 

during rail movements, the shipment shall comply with the placarding provisions of 49 CFR 

Part 172, Subpart F; and (4) cargo tanks, multi-unit tank car tanks, portable tanks, and 

intermodal portable tanks containing hazardous materials are not permitted in this service. 

10. Each RailMate bogie that does not have safety appliances that are compliant with Federal 

regulations shall be stenciled on each side, in clearly legible letters not less than 6 inches 

high, “NO SAFETY APPLIANCES” and “DO NOT RIDE,” at a location that is visible to a 

person walking at track level beside the unit. 

11. CP shall issue instructions prohibiting anyone from riding RailMate equipment, unless it is a 

bidirectional unit specifically designed to be ridden and it is not stenciled as required in 

Condition10. Strict enforcement of this rule is required. 

12. New terminal facilities for RailMate equipment shall, to the extent feasible, be designed to 

limit the frequency and length of shove movements. Shove movements of RailMate 

equipment, with personnel riding a RailMate bidirectional transition unit equipped with 

compliant safety appliances, shall not exceed 10 mph. 

13. Whenever a shoving move of RailMate equipment is required, the movement shall be 

protected by either: (1) an individual riding a RailMate bidirectional transition unit 

specifically designed to be ridden; or (2) an individual walking with the movement, with the 

speed of the move not to exceed that of the individual walking. 

14. Maximum speed of RailMate train is 60 mph. 
Motive Power and Equipment Compliance Manual 

B – 45

15. Piston travel at initial terminal shall be 2 +/- 1⁄4 inches. 

16. The air brake shall be considered ineffective at 31⁄4 inches of piston travel. 

17. CP shall ensure that all personnel (including contractors) responsible for assembly, 

inspection, maintenance, and operation of RailMate equipment have been trained and 

qualified to perform those duties prior to undertaking them, including instruction in the 

provisions of this waiver pertinent to their duties. Training for railroad operating and 

mechanical personnel, who may encounter the equipment, shall specifically include training 

necessary to provide for their personal safety (including Blue Flag Rule) when working on 

or in proximity to the equipment. Supervisors shall also possess the knowledge and skills 

required of employees subject to their direct supervision. All personnel required to receive 

training subject to this condition shall have their qualifications for duties related to RailMate 

equipment documented in the same manner provided for in 49 CFR Part 232. Signed and 

dated copies of all training provided to personnel in accordance with this condition shall be 

kept on file at each RailMate operating terminal. 

18. CP shall maintain adequate records to demonstrate the current qualification status of all 

personnel assigned to operate, inspect, test, and maintain RailMate equipment. 

19. CP supervisors or their representatives shall exercise oversight to ensure that all tasks and 

maintenance/repair practices are performed in accordance with the railroad’s written 

procedures, applicable standards, and recommended practices of the Association of 

American Railroads (AAR) interchange rules, and all applicable Federal regulatory 

requirements. 

20. CP shall immediately report equipment and/or component failures and any accident, 

incident, or injury involving RailMate equipment to FRA’s Office of Safety Assurance and 

Compliance in Washington, DC. 

21. FRA reserves the right to modify or rescind this waiver at any time upon receipt of 

information pertaining to the safety of rail operations or in the event of noncompliance with 

any of the conditions of this waiver. 

22. This waiver is granted for a 5-year period from the date of this letter. FRA reserves the 

right to extend this waiver if conditions warrant and CP has made a written request for an 

extension to FRA’s Office of Safety Assurance and Compliance at least 6 months prior to 

the expiration date. 
`Appendix C

Illustrative Locomotive Plates

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Plate S - 2
Federal Railroad Administration

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Plate S - 3

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Plate S - 4
Motive Power and Equipment Enforcement Manual

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April 13, 2007

Draft Revision 0

Statistically Driven Inspection

Guidance

for

Motive Power & Equipment

Inspectors and Safety Specialists

Federal Railroad Administration

Office of Safety Assurance and Compliance

Motive Power & Equipment (MP&E) Division

April 2007
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April 13, 2007 

Draft Revision 0

Statistically-Driven Inspection Guidance

for

Motive Power & Equipment Inspectors and Safety Specialists

Overview: The FRA has collected railroad safety data for decades, and now has the information

and databases available for direct use by Motive Power & Equipment (MP&E) Inspectors via the

Internet. With increasing traffic over the North American freight railroads with ever-increasing

axle loads and payloads, increased demand for high-speed passenger trains, new-technology

commuter railroad equipment and service, new wayside train inspection devices, and ever

increasing duties for MP&E inspectors, the use of statistically driven inspections will provide a

baseline to plan inspection itineraries and optimize the regulatory enforcement strategies and use

of the MP&E inspection workforce. 

Background: FRA developed the National Inspection Plan (NIP) that provides the overall

inspection philosophy for the Office of Safety Assurance and Compliance. In conjunction with

the NIP, each FRA Region develops an Annual Inspection Plan tailored to the specific railroads,

traffic, and personnel unique to their Region. The guidance provided, herein, builds upon the

Regional Inspection Plans (RIP’s), and does not supercede them. By formulating data queries

tailored to an Inspector’s territory, a report unique to that area or railroad can be generated,

indicating the “top five” or more causes of accidents/incidents, train accidents, or casualties

historically found at that location and also the identification of detrimental or higher “safety

risk” trends. In addition, rail car and locomotive defects can be identified in the RISPC Database

and additional trend-line “drill-downs” performed.

Applicability: At this time the“Drill-down” procedures to evaluate potential trends in the safety

data will only be applied to the Accident/Incident, Train Accident, and Casualty Databases. In

accordance with the criteria stated in the Regional Inspection Plan, an MP&E Inspector or Safety

Specialist will select the railroad(s) and location(s) to be inspected based upon past experience

and knowledge of traffic patterns. This also builds on the “expert” knowledge base of the

MP&E Inspector. Based upon the railroad selected, the corresponding Class of railroad is

determined: Class I (Major Railroad), II (Regional), or III (Shortline) and noted for use in

generating the “Drill-down” Report (see “Drill-down Procedure, page 5).

Pilot Project: To validate the statistically-driven inspection procedures developed by the

MP&E Division, Inspectors from FRA’s Region 2 participated in a short evaluation program in

2006 (Pilot Project) to use the goals of the NIP, RIP, and FRA’s Safety Database to predict what

type of defects with a potential to cause a derailment or serious incident may be present in the

Inspector’s territory. The locations visited by the project team were CSX Transportation at

Cumberland, Maryland and Crofton, West Virginia; Appalachian and Ohio Railroad at

Buckhannon, West Virginia; and Norfolk Southern Railway (NS) at Pittsburgh, Pennsylvania. 
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The findings from this pilot project were that the methodology proposed by the MP&E Division

was viable in determining the mechanical issues associated with a railroad/region. Further,

FRA’s MP&E’s Inspectors found the proposed methodology, and FRA’s safety data on the web

site practical and easy to use. 

The “top-five” mechanical causes for derailment were identified for the example inspection area,

Allegheny County, Maryland. The validation team visited the location(s) and the process for

determining the “top-five” items for all railroads and just for Region 2 were found not to be

cumbersome, as there are similarities between these two lists. Wheel-caused derailments were

indicated in the query as being one of the top-five causes. During the inspection on CSXT at

Cumberland, Maryland a high-flange wheel was identified. However, the Inspectors’ knowledge

of his/her inspection locations is key to the success of this approach as the number of

accidents/incidents is not statistically significant (too few incidents randomly occurring)

compared to the number of car movements per year . 

During the pilot project it was discovered that the FRA safety database not appear to have

reported all accidents that occurred, and in some cases the reported cause contained errors. For

example, the Appalachian and Ohio Railroad filed four accident/incident reports between May,

2005, and February, 2006. However, the FRA database only indicated three derailments. One of

the reports indicated a cause code of “T-316" for track, but the actual cause was found to be a

burnt-off wheel journal bearing. Thus, it was verified that FRA MP&E Inspectors are not

working with a “perfect” database and the Inspector’s knowledge base is ever more important in

cross checking of “drill-down” data summaries and determining “high-risk” causes and in

identifying detrimental trends.

Based upon the experience gained by the first field pilot trial, a refinement was made to the dataacquisition procedures. A matrix may be created at the Regional level for each inspection point

that correlates to an identifier (symbol) of a train which was involved in an accident/incident to

the origination location. That is the point where an inspection can yield a benefit to prevent a

future accident/incident, as the defect that caused the derailment may have been present at the

origin location. By using the top-five causes of accident/incident identified from a query, a

search of the accident/incident report will provide the train identifier (symbol). The procedure

will then tie the train involved in the accident/incident to the originating point where a focused

inspection can then be scheduled. Thus, the procedure solves for the “where” and “what” to

inspect for at the originating location.

A second validation inspection was conducted at the NS Conway Yard, Conway, PA using the

revised procedures. Similar results to the first inspection were observed in that the team found

the procures easy to use, and the “Top-five” derailment causing defects verified only one defect

related to those being given focused attention was identified (related to defective roller

bearings).

Based upon a review of FRA’s safety database there are very few MP&E-caused

accidents/incidents. From January 2002, to December 2005, there were only 7
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accidents/incidents in Region 2 in Maryland. Their causes were: brakes cause code (E0) - two

(2) incidents, axles & journal bearings (E5) - two (2) incidents, coupler & draft system (E3) -

one (1) incident, truck components (E4) - one (1) incident, and wheels (E6) - one (1) . With the

number of accidents/incidents being so few, the potential for finding a targeted defect by trend

analysis is extremely low. However, one of the “top-five” causes, high-flange wheel was found

in Cumberland yard on CSX in an outbound train during the pilot project inspection.

Pilot Project Summary: The proposed procedures for using a “drill-down” method of

predicting elevated levels of mechanical defects were found easy to use by the MP&E

Inspectors. One of the “top-five” causes of derailment nationwide was identified during the pilot

program inspection. However, the number of MP&E-related defects that cause derailments are

very low on an annual basis, and extremely low on an individual Regional or inspection location

(not statistically significant). Therefore, the overall usefulness of a statistical approach to defect

identification should only be used in combination with the “expert” judgement of the MP&E

Inspector and trends develops on a nationwide basis as identifying in safety oversight of the

railroads and received and review of headquarters trends analysis.

The number of MP&E related defects that may cause a derailment appear to be too low to be

statistically significant. However, a defect predicted to be present was identified during both

validation inspections. Based upon even these marginal results, a program could be developed to

use a statistically driven approach to assist MP&E Inspectors in the identification of critical

safety defects. If an Inspector queries the FRA database on a bi-annual basis to develop a list of

the “top-five” causes of derailment on a nationwide and Regional basis, they will have a

heightened awareness of these defects during their regular inspections. Later sections in the in

the MP&E Compliance Manual will be useful in explaining the process and providing the

MP&E Inspectors with examples using the database and trend charts (see page 6). It is obvious

that this process is not a “perfect science” and greatly dependent upon the knowledge base and

judgement of the MP&E Inspector.
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“Drill-down” Procedure: The“Drill-down” procedures below apply only to the following

databases:

Accident / Incident, Train Accident, and Casualty Database

Inspection Data Selection: 

1. The MP&E Inspector or Safety Specialist selects the railroad to inspect based upon past

experience, and knowledge of traffic patterns in accordance with the criteria stated in the

Regional Inspection Plan; also, in consultation with the Regional MP&E Safety

Specialist.

 

2. Based upon the railroad selected, the corresponding Class of railroad is determined, such

as Class I (Major Railroad), II (Regional), or III (Shortline) and noted for use.

3. Upon selecting the railroad and Class, the MP&E Inspector will then access the Internet,

and go to the FRA’s Home Page at www.FRA.DOT.GOV. On the Home Page, select the

Icon for “SAFETY”, then open “Safety Data”. There are nine (9) categories to choose

from regarding safety data, and many subcategories.

4. From the list of categories and subcategories, select the type of information desired, such

as 2 - Query Accident/Incident Trends, 3 - Train Accidents, or 4 - Casualties for MP&E

related data.

“Drill-Down” for the “Top Five” Causes of Derailments

5. For example, the Inspector selects “2-Query Accident/Incident Trends, 2.01 Train

Accidents.” From the Railroad Group, select Class I Railroads; then Region 6; then State

- Missouri; then Type of Accident - Derailment; then Primary Cause of Accident -

Mechanical and Electrical Failures; and finally the Inspector selects the time period (by

year) 2005. Click on “Generate Report”, and the “drill-down” results will be displayed. 

The “Top Five” causes of derailment, related to Mechanical and Electrical Failures are

viewed as:

Year 2005 Results to Date: 

• E40C Side bearing clearance insufficient; 

• E46C Truck bolster stiff; 

• E0HC Hnd brk link and/or connect defect; 

• E21C Center sill broken or bent; 

• E34C Draft gear/mechanism broke/defective

6. This process can then be repeated to assess other Accident/Incident trends by the MP&E

Inspectors for as many states and locations as desired.
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Focused Enforcement: Focused enforcement entails concentrating enforcement efforts

primarily on the types of violations most likely to cause an actual train accident or injury. FRA’s

accident/injury database provides a wealth of information on what these leading causes of

accidents and injuries are. The basic principle here is allocating our finite enforcement resources

on those areas where improvements in compliance are most likely to produce maximum safety

benefits. The principle is the same with regard to allocating inspection resources; as discussed in

a separate document on inspections, we need to use available information on safety risk criteria

to better guide our selection of inspection priorities.

FRA Inspectors shall utilize FRA’s accident, injury, and inspection data to gain better insight

into the types of violations that are actually causing large numbers of accidents and injuries. 

While much of the information is already available to the field, FRA will distribute to the field

data summaries showing the leading causes of train accidents and injuries by safety discipline,

cause code, and regulatory section. The data will be industry-wide and broken down by railroad. 

With this information, Inspectors will be better equipped to weigh the discretion criteria

concerning the inherent seriousness of violations and the level of risk posed in specific

circumstances. This is not to suggest that enforcement decisions are to become entirely driven

by data. Direct observations and experience will always be necessary elements of these

decisions. However, because the agency has adopted certain performance goals linked directly

to reducing the rate of certain unsafe events, we need to make better use of the data we collect to

help guide our achievement of those goals.

In-depth accident analyses are conducted to determine if any laws, rules, or orders within FRA’s

jurisdiction have been violated and what remedial action should be taken. In addition, Inspectors

must study accident trends in their inspection territory, especially those attributed to human

factors and mechanical practices; to include inspections, tests and repairs. Information is

available for each railroad in the Inspector’s territory and will be helpful in outlining inspection

plans and setting safety priorities. Site-specific inspections should be performed on the basis of

each Inspector’s knowledge of enforcement areas requiring more attention to ensure safety. An

Inspector’s knowledge of each railroad within the inspection territory should determine the types

of inspections which must be performed. For example, if a recent human factors-caused accident

was related to an improper air brake inspection, concentrated inspections of the railroad’s air

brake inspections should be conducted at various times throughout a 24-hour period, to include

weekends. Where Inspectors are focusing on leading causes of accidents and injuries, their

violation reports should summarize the factors underlying their decision. 

In the meantime, Inspectors are encouraged to make use of data already at their disposal,

including accident data, inspection data, and their own experience about the most important

safety hazards. Inspectors should give this information great weight and strongly consider

enforcement action whenever these especially unsafe conditions occur, with a goal of

maximizing the safety return on enforcement efforts. While some enforcement actions will

continue to be necessary on matters that are not likely to actually cause accidents or injuries, but

violate regulations that are important underpinnings of an effective regulatory program (e.g.,

recordkeeping), those matters that are serious safety concerns are more likely to be the prime

candidates for enforcement actions. Reporting, recordkeeping, and inspection violations become

more important to the extent they are widespread and/or bear directly on compliance with

substantive requirements.
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Over time, this more careful focus on how enforcement discretion is exercised should

significantly improve FRA’s utilization of limited resources regarding compliance oversight. On

the other hand, as we refine the process, we may decide to adopt a “zero tolerance” (i.e., always

enforce) policy for the most egregious and flagrant violations. The goal is not to achieve a

particular volume of enforcement actions on the high or low side. The goal is a compliance

program in which enforcement discretion is routinely exercised in a commonsense way to

address important problems that more cooperative methods have not resolved.

Interpretation of the Nationwide Mechanical Equipment Accident/Incident Statistics &

Trends (Bi-annual Report): The MP&E Division reviews the accident/incident database on a

continuous basis throughout the year. A report is prepared tailored to a specific railroad on a biannual basis (i.e. UP, CSX, NS, BNSF, KCS, Amtrak etc.). These reports display the nationwide

equipment caused accident/incident trend, and recommendations from the MP&E Division to the

Regional Safety Specialists and Inspectors regarding focus areas.

The analysis process for these bi-annual reports uses a “feed-back”loop, in that it takes raw data

that has been organized and interpreted looking for trends. Then the charts are reviewed with

Regional MP&E Specialists, representatives from the railroads, and the FRA’s RSOM’s. The

Regional MP&E Inspectors develop focused inspections, the railroads action plans, and the

RSOM’s an oversight plan based upon the trends and “top-10 defects”.

From the FRA’s Safety Database, Inspectors can develop queries based upon “All Regions” or

just their own for the “Primary Cause of Accidents” (for MP&E use “Mechanical and Electrical

Failures”). The output from this query will yield the “top-10" from the Primary Cause Code

(“E” (for equipment) XX (specific defect code) and “C” car or “L” (for car/locomotive). The

raw data is then summarized into a series of charts based upon the actual count of incidents, then

normalized by million train-miles. By normalizing the data the MP&E Inspector can compare a

large Class I railroad with other railroads, regardless of class.

By graphing the raw and again for the normalized data the MP&E Inspector and Specialist will

gain a powerful tool to see trends in the data. One caution is that for many of the MP&E causes

of accidents/incidents, the number on a nationwide basis is very small, and on a Regional or

county level may be so small that no trend can be established. The other issue is that large

variations in the data may be observed, as the count from a railroad may go from 1 occurrence in

a year to three, then the following year to zero. These small changes in the count will yield a

large change in the graph. By normalizing the count by million-train miles, then comparing the

rate to other railroads within the Class, the MP&E Inspector will be able to make a determination

whether the change is of concern, or statically not important. 

Examples of the FRA Safety Database outputs for selected defects such as: The Total MP&E

Caused A/I Count, Axle-Caused, and Journal Bering Overheated Caused are provided for

reference, along with their corresponding normalized rate charts. In addition, the MP&E

Division developed a “Bad-Actor” Chart with targeted area for focused inspections on various

railroads. If an “X” is annotated on the matrix, then that specific defect (such as E30-30 Coupler

& Draft Gear) is either higher in count or rate than that nationwide average, or the slope of the

line on the graph indicates an undesirable increase (trend) over the previous 2-3 years.
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In summary, by developing a specialized “top-10" list of defects, an MP&E Inspector will gain

insight into the type of mechanical defects that are causing accidents/incidents on a nationwide

and/or Regional level. By paying close attention to these type of defects when conducting

routine inspections, more potentially unsafe conditions will be identified and re-mediated in the

yard before they can become an Accident/Incident statistic. 
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