Two-Person Train Crews After Waiver Withdrawals

Two-person train crews remain the federal safety baseline after First Coast Railroad and Georgia Central Railroad withdrew petitions seeking Federal Railroad Administration approval to operate trains with one person in the locomotive cab. Their requests were the first submitted under the waiver process created alongside FRA’s 2024 Train Crew Size Safety Requirements Rule.

The withdrawals were announced on August 27. Neither railroad provided a reason for withdrawing its petition.

The 2024 rule established two-person crews as the federal safety baseline after FRA considered more than 13,500 public comments. This made the First Coast and Georgia Central applications the first tests of the FRA crew waiver process allowing railroads to seek exceptions from that requirement.

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Unions oppose one-person crew operations

SMART-TD opposed both petitions. The union said the cases carried broader significance as the first attempts to obtain waivers under the new framework and could have shaped subsequent applications. Although SMART-TD does not represent employees at either railroad, it said it intervened because of the implications it saw for two-person train crews.

BLET separately opposed Georgia Central’s request. BLET said it is the only union representing workers on Georgia Central, a 211-mile Genesee & Wyoming short line operating between Savannah and Macon, Georgia. Employees voted for BLET representation in an election certified by the National Mediation Board in October 2024.

Georgia Central submitted its waiver petition in late 2025, with BLET subsequently filing a protest with FRA. The union described the railroad’s August 27 withdrawal as a victory for its members and railroad safety.

Safety concerns over the FRA crew waiver requests

SMART-TD filed its objections in FRA dockets FRA-2026-0562 and FRA-2026-0563. According to the union, both railroads proposed taking the conductor off the locomotive and having that employee follow the train by road in a truck.

SMART-TD argued that the proposed arrangement lacked human factors studies and field testing, while leaving “close proximity” undefined. It also questioned what would happen if a conductor traveling by highway was blocked at a crossing and unable to reach a derailment or grade-crossing collision.

The union also said the petitions contained gaps and contradictions involving hazardous-material handling, operating rules and accident data that FRA and the public were supposed to be able to review.

BLET raised additional concerns about Georgia Central’s proposal. It said the railroad set no maximum limits for train length, number of cars, tonnage, distance traveled during a single tour of duty or duty time. The union also said the request lacked specific fatigue-management provisions.

According to BLET, the proposed route included approximately 360 crossings, many of which were not actively controlled. The union further said Georgia Central had not accounted for hazardous-material risks in the event of an accident.

BLET National President Mark Wallace stated the union’s position in comments opposing the waiver.

“The BLET has consistently opposed one-person crew operations,”

“There is no substitute for a second crewmember in the cab. We do not support exceptions. There should always be a certified locomotive engineer and a certified conductor in the cab of a locomotive. There are too many hazards both within and outside of the cab to be safely and effectively managed with a single person.”

Wallace also rejected Georgia Central’s proposal that an alerter could replace the role of a second crewmember in the locomotive cab.

“The GC has proposed that the alerter can replace the role of a second crewmember within the cab of the locomotive. This is absurd,”

“Expecting a single crewmember to operate safely over this type of territory while simultaneously maintaining heightened vigilance for track conditions, operational hazards, signal compliance, and surrounding environmental factors imposes an unreasonable and unsafe workload.

“Even under normal operating conditions, maintaining situational awareness over extended periods of operation can be demanding for a two-person crew. Requiring one individual to independently identify and respond to hazards associated with degraded infrastructure substantially increases the risk of missed warnings, delayed reactions, fatigue-related errors, and reduced ability to respond effectively during emergencies or abnormal conditions.”

Two-person train crews remain part of wider dispute

The withdrawals follow earlier regulatory and legal disputes over the federal two-person crew requirement. SMART-TD said it spent years helping build the record that led FRA to finalize the rule in 2024 and that its legal team stood alongside FRA attorneys in litigation before the U.S. Court of Appeals for the Eleventh Circuit. BLET likewise noted FRA’s defense of the rule before that court.

SMART-TD characterized the withdrawal of the two applications as another result in its continuing campaign against one-person crew operations. The union emphasized that these first attempts to secure waivers ended before FRA issued decisions on the petitions.

Context

Under FRA’s 2024 rule, railroads seeking to start certain one-person train operations must go through a special-approval process rather than simply reducing crew size. The process includes a risk assessment for the proposed operation, and FRA publishes each petition for public comment before making a decision. The assessment is intended to examine whether the proposed one-person operation, with its planned safeguards in place, would be as safe as or safer than an operation using the two-person minimum crew.

SMART-TD also said its campaign is not finished. It is seeking congressional passage of the Railroad Safety Act with bipartisan support for two-person crews through both chambers of Congress and said members would receive requests to contact legislators as part of that effort.

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