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Compliance

243 Compliance Checklist

The deadline to submit initial training programs is just days away. But what about the other 243 requirements? Here is a checklist that breaks down what you have to do to be compliant with the regulation. Note that timelines provided are for all railroad contractors and other railroads who are not a Class 1 railroad or intercity/commuter passenger railroad with 400k or more annual employee work hours.

1. Submit, Adopt, and Comply with Program Requirements §§243.109(a), 243.109(b)

Timing: By May 1, 2021

2. Serve a Copy to Labor Organizations §243.109(d)

Timing: At the same time as the submission for §§243.109(a), 243.109(b)

Note: If a training program is not required to be submitted to FRA, it is not required to be submitted to the labor organization.

3. Begin Periodic Oversight §243.205

Timing: Implement upon submission of programs

4. Maintain List of Contractors §243.209

Timing: Implement upon submission of programs

5. Designate (Grandfather in) Existing Employees

Timing: Complete documentation by January 1, 2022

6. Annual Review §243.207

Timing: Annually after program submission

7. Maintain Records §243.203

Timing: Implement upon submission of programs

Are you still feeling stuck on your 243 training programs or not sure how to get started? We can help! We have helped Class 1, short line, and regional railroads, and contractors prepare for 243. Contact us at info@sparkts.net

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