FRA's Two-Person Crew Rule Costs the Rail Industry $6.6 Million Over a Decade

On June 10, 2024, the Federal Railroad Administration's Train Crew Size Safety Requirements rule took effect — the first federal regulation to set a minimum crew size for U.S. freight trains.▸ Rail unions had sought it for years; the rail industry sued to block it. What the rule actually changes, in dollar terms, is small. FRA's own regulatory impact analysis puts the ten-year, industry-wide compliance cost at $6,636,876, discounted at 7% — because, as the rule itself states, "[the] majority of trains operate with two crewmembers" already. The regulation's real content is a permission process for the exceptions: FRA counted 73 one-person train crew operations nationwide, all at small Class III (short line) railroads, that now have to notify the agency, install alerters, and file annual reports to keep running.

FRA's rulemaking didn't have to prove two-person crews are safer — the agency says plainly it "discusses the benefits but does not have sufficient data to monetize" them, because it doesn't have to change what most railroads already do.▸ Instead the money goes to paperwork and hardware for the exceptions: locomotive alerters (devices that stop a train if a lone engineer becomes unresponsive) account for $4,427,708 of the total, two-thirds of every dollar the rule costs. The rest is process — risk assessments, special approvals, notifications, annual reports, and FRA's own cost of administering all of it.

That $6.6 million is spread across a regulated universe of 784 railroads — "excluding tourist railroads not on the general system," in FRA's own count — of which only a sliver run one-person crews at all.▸ Class I railroads (the large freight carriers) mostly abandoned one-person operation years ago under pressure from labor agreements; it's the short lines that kept it, and it's short lines the rule mostly regulates.

The other way to read the $6.6 million figure is against the workforce it touches.▸ The occupations a "crew" is made of — locomotive engineers and conductors — employed a combined 79,910 people nationwide as of the U.S. Bureau of Labor Statistics's May 2025 Occupational Employment and Wage Statistics survey: 33,470 locomotive engineers and 46,440 conductors and yardmasters. FRA's 73 counted one-person operations are a rounding error against that workforce — the rule's compliance cost is not being paid to add or remove jobs at any scale visible in national labor statistics; it's being paid to document an exception that already existed.

The two roles aren't interchangeable and aren't paid the same.▸ Locomotive engineers, who operate the train, earn a national annual mean wage of $85,900; conductors and yardmasters, who manage the train's movement, switching, and safety checks from the ground and the cab, earn $79,100 — both per the same BLS survey. A one-person operation eliminates one of these two positions per train; which one depends on the railroad's staffing model, and FRA's rule does not specify which.

The rule was not written on a blank slate.▸ FRA's own accident data cited in the rulemaking shows the rate of human-factor-caused accidents rose from 0.95 per million train miles in 2013 to 1.34 in 2022 — a 41.1% increase — as the agency built its safety case. Rail unions BLET and SMART-TD, which represent "the vast majority of operating train crew workers across the nation," asked FRA to go further and "mandate that two-person crews are the standard." The Association of American Railroads opposes the rule outright, countering with FRA's own 2019 finding that "accident/incident data does not support a train crew staffing regulation" and arguing staffing decisions belong in collective bargaining, not federal rule. Multiple Class I railroads — including Union Pacific, BNSF, and others — sued to void the rule; the consolidated challenge is before the 11th Circuit Court of Appeals, and as of this writing the rule remains in effect while that litigation continues.

The $6.6 million figure and its category breakdown are FRA's own figures from the rule's regulatory impact analysis, not this piece's calculation. The 73-operation count is FRA's own pre-rule estimate for Class III railroads specifically; it does not capture whatever new one-person operations Class I or Class II railroads may seek special approval for under the rule's process. Employment and wage figures are national means from BLS's May 2025 survey, the most recent available as of this writing, and are not broken out by railroad class or by which crew position a given one-person operation eliminates.