Fight for Fairness: Help advocate for safety in rail and transit 

December 2, 2024

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We need your help in our ongoing fight to protect our mutual safety and well-being. We face three rule changes and have an opportunity to share what we believe the consequences will be. Whether you work in rail or transit, your action today can help make a difference. 

Visit Regulations.gov to send your comment for the three issues listed below. By working together, we can help ensure that those who make the decisions understand how dangerous these changes will be. Don’t wait, act now! 

Today’s critical proposals and what’s at stake 

SMART-TD is responding to three important public comment deadlines with the Federal Railroad Administration (FRA). These proposals threaten our safety and the integrity of our work: 

  1. BNSF’s attack on injury reports: BNSF wants to stop posting work-related injury and illness information in crew rooms. This change would undermine transparency and hinder workers’ ability to stay informed about potential health and safety hazards. Docket No. FRA-2018-0083 
  1. CPKC’s desire to skip brake tests: CPKC is seeking approval to skip crucial single-car air brake tests on cars with known defects. This puts workers and the public at increased risk, and we cannot allow it. Docket No. FRA-2024-0079 
  1. Open C3RS (Confidential Close Call Reporting System) to dispatchers: This system provides a private channel for employees to report near-misses without the risk of retaliation. We want to support this proposal; it is essential for anyone to be able to report safety problems in the workplace. C3RS should be standardized. The public comment on C3RS today is aimed at including Dispatchers in the C3RS system. Docket No. FRA-2024-0089 

These proposals may seem separate, but they all share a common goal: cutting corners on safety for profit. SMART-TD is committed to standing up to these dangerous changes and ensuring that our workers’ safety is never compromised. 

How to send a public comment 

We need your help to make sure our collective voice is as strong as possible. Here’s how you can get involved: 

  1. Submit Your Own Comment: 
  • Visit Regulations.gov to submit a comment on any of these proposals. The more personal and detailed your comment, the more impact it will have. Share how these changes affect your daily work, safety, and rights. Comments can be submitted anonymously to protect your privacy. 
  • On Regulations.gov, you can search by putting the Docket Number in the search bar. When you find the correct “Petition for Waiver of Compliance,” click on the blue “Comment” tab in the upper left part of the screen to submit your personal statement on the topic.  
  1. Encourage Local Legislative Representatives to Act: 
  • If you are a Legislative Representative, now is the time to step up. Your involvement in the public comment process is critical to strengthening our collective impact. The more local leaders who participate, the more powerful our efforts will be. 

The public comment process is your chance to speak up 

Every time the FRA receives a proposal to change safety procedures or make exceptions to regulations, they invite the public to comment. This is a vital opportunity to voice our concerns. This does influence decisions that will affect our jobs, safety, and livelihoods. 

The public comment period typically lasts from 30 to 90 days. The railroads and the American Association of Railroads (AAR) will often flood the FRA with multiple requests, particularly during busy times like the holidays, assuming we will be too busy to write a comment. Don’t let this tactic work! Take a few minutes today and let your voice be heard. 

SMART-TD never stops: responding to multiple agencies 

Our commitment to safety goes beyond the FRA. We are actively responding to eight additional opportunities this month. Between now and the end of the year we will address a total of 11 public comment submissions across various agencies—including the FRA, FTA, PHMSA, and OSHA. These proposals affect our railroad, bus, and transit members, and we are dedicated to ensuring that our voices are heard loud and clear. 

Let’s Keep Fighting for Safety, Fairness, and Respect 

The SMART-TD rail and transit union is committed to strengthening our railroad, bus, and transit members. We will not back down from the fight for our safety, rights, and the future of our industries. Together, we can make sure that railroads and transit agencies can’t push through dangerous changes without hearing from those who are on the front lines every day. 

Take action today by visiting Regulations.gov and submitting your comment. Let’s continue fighting for safer working conditions, fair treatment, and the protection of our livelihoods. Together, we will never back down.