These comments are submitted in response to the March 25, 2020 decision by the Federal Railroad Administration (“FRA”) granting the Association of American Railroads (“AAR”), the American Short Line and Regional Railroad Associations (“ASLRRA”) and the American Public Transportation Association (“APTA”) (collectively “Associations”) dozens of waivers of railroad safety regulations, in response to the Associations’ joint petition for unprecedented regulatory relief during the Coronavirus (“COVID-19”) pandemic. For the most part, these waivers extend various regulatory deadlines for compliance by sixty (60) days.
The railroad Labor Organizations identified above (“Labor Organizations”) are the collective bargaining representatives for the vast majority of railroad industry workers engaged in train operations, train dispatching, signal, maintenance of way and mechanical maintenance, inspection, testing, and repair on passenger and freight railroads throughout the United States. The Labor Organizations and their individual and collective memberships have a direct safety interest in FRA’s decision. The classes or crafts of employees represented by the Labor Organizations include those who will be directly affected by the waiver of the safety regulations discussed in these comments. The Labor Organizations appreciate the opportunity to comment; however, we stress that these comments only summarize our most significant concerns. Between the massive scope of the Associations’ petition (and FRA’s relief), and notice and comment periods normally allowed for waivers being suspended for Emergency Relief Docket matters, we have struggled to provide the below comments even on this expedited timeline.

READ ENTIRE DOCUMENT HERE: Joint Rail Comments to the FRA