SAFETY AND SECURITY: Observations on the Company’s Annual Physical Exam Requirement for Locomotive Engineers

This report communicates considerations for company management if it reinstates the annual physical exam requirement for locomotive engineers, which the company suspended in August 2021 in part because of the COVID-19 pandemic.

Prior to the suspension, we found that about one-third of locomotive engineers did not meet the company’s self-imposed requirement to pass an annual physical exam. Company reports showed, however, that they had passed a triennial exam to meet related Federal Railroad Administration requirements. Several factors likely contributed to engineers not fulfilling the annual requirement, including that the company had not yet designated in policy a senior accountable official or developed processes to fully enforce it.

We provided two considerations for management if the company reinstates the requirement, including adopting more rigorous processes to enforce it and designating in policy a senior accountable official to ensure supervisors enforce it.