Do Railroad Contractors Need an FRA Approval Letter?

“Do I need an FRA approval letter for my contractor training program?”

That’s the question we hear frequently from contractors. The answer depends on a few key factors!

Not every FRA training program needs to be submitted.

While some programs still require formal submission to the FRA, many no longer do. That said, contractors are still responsible for having a compliant training program in place—even if it doesn’t need to be submitted.

Below are examples of training programs that contractors still need under federal railroad safety regulations—but no longer have to submit to the FRA.

• Bridge Safety Standards (49 CFR Part 214 Subpart B)

• Roadway Worker Protection (49 CFR Part 214 Subpart C)

• Roadway Maintenance Machine Operator (§214.355)

• Drug & Alcohol Training for Supervisors (§219.11(g))

Some examples of training programs that require submission include: 

• Railroad Freight Car Safety Standards (49 CFR Part 215)

• Locomotive Safety Standards (49 CFR Part 229)

• Blue Signal Protection of Workers (49 CFR Part 218 Subpart B)

• Signal Training (CFR Parts 233, 234, 235 & 236)

For a full list of training programs that don’t require submission, see pages 8–11 of the FRA Compliance Manual (available here).

Whether or not your training program needs to be submitted, you’re still responsible for meeting the 243 training requirements for any safety-related task covered under the regulation.

Contractors Are No Longer Getting a Grandfather Pass on 243
More contractors are getting asked for 243 approval letters—instead of being grandfathered in like before.

Contractors routinely report to us:

“We’re being held to the same 243 standards as Class I and short lines now.”

The next question we hear after explaining that not all programs require submission is:

"If I don't need to submit my training program to FRA, why is my railroad customer requiring an FRA approval letter?" 

There’s still confusion in the industry about whether contractors are required to get FRA approval letters for their 243 training programs. Much of the uncertainty comes from the language in §243.107(a), which states:

“An employer who provides or is responsible for the training of safety-related railroad employees shall submit its training program to FRA for review and approval.”

Several railroads have pointed to this language when asking contractors for documentation that proves they’re compliant with 243.

What Contractors Need to Know About 243 Approval Letters

Not every request from a railroad is based on a regulatory requirement. Some are contractual. That means you’ll need to work directly with your customers to understand what documentation they expect. But from a regulatory standpoint, there is no requirement for contractors to get FRA approval letters for training programs that no longer require submission.

✅ Why are Contractors Being Asked For FRA Approval Letters. What’s Changed?

• Greater scrutiny on contractors. You’re just as responsible as Class I and short line employers.
• Broader enforcement.More railroads are actively checking contractors for 243 compliance before work begins.
• Documentation matters. A contractor’s FRA Approval Letter proves your training program meets regulatory benchmarks.

Why Contractors Need An Approval Letter

If you’re a contractor performing any safety‑regulated work—track repair, signal testing, roadway maintenance—you must have a submitted and approved training program under Part 243. The letter confirms:

1. Your program meets §243.101‑.113 standards.
2. You’ve submitted it to FRA via their portal, not just adopted training internally.

What Happens If You Don’t

• You risk being barred from assignments or fines.
• Your railroad clients may be found non‑compliant during audits.
• You’ll face operational delays if you’re missing key documentation.

🎯 How RailTasker Helps

Our Rail Tasker 243 Checklist software module is a top request from contractors—and for good reason. It ensures you:

• Track all required course elements against FRA standards.
• Submit paperwork and program documentation directly via the platform.
• Store your official FRA Approval Letter and related records in one place.

Rail Tasker users say it’s made submitting their 243 program one of the easiest parts of the process.

Got Questions—or Ready to See Rail Tasker in Action?

Explore how the 243 module in Rail Tasker can automate your compliance tasks, keep you ahead of audits, and take the guesswork out of FRA requirements.

• Read our post: How to Submit Your 243 Program to FRA
• Watch our on-demand webinar: A Quick Guide to 243
• See it live: request a quick demo and we’ll walk you through step by step.

👉 Request a Rail Tasker demo