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On-the-Job Training (OJT), Compliance

Flipping the Perspective of 49 CFR Part 243

If you are feeling stuck trying to get started with 49 CFR Part 243, you are not alone. However, I have found that simply looking at the requirements from a different perspective helps get most people moving again.

The confusion starts with how the industry has emphasized guidance and content by CFR Parts

In general, the guidance and many model program providers have emphasized this regulation should be analyzed by going through each of the CFR Parts under the scope of Part 243. And, starting with Part 209 and ending with Part 272, the FRA OJT Matrix provides 1,500+ lines of data and guidance on what type of training is required, organized by each paragraph of the regulation with a long list of job duties squeezed into one column. I have heard others say this approach is easier and allows employers to pick from what is needed like an à la carte menu.

And, I understand why, at first glance, this seems like a practical approach to tackle 243. But here are a few reasons why I think it results in people feeling overwhelmed:

The Alternative

The alternative is to focus on the application of what is required in 243 based on what jobs employees perform, which means organizing information and your programs by job categories or duties. There is a little more work on the front end, but it pays dividends:

I know, this is easier said than done. However, I have helped 5 Class 1 railroads and countless other contractors and short line railroads with their 243 planning and I know it can be done. To get my clients started, we have a training curriculum that is organized by common industry job duties and a version of the FRA OJT Matrix that is easily filtered by job duty versus CFR Part. This content and approach integrates nearly 10 years of preparing for 243, industry task analysis, and instructional design concepts to make 243 as easy as possible. The result is a simple implementation strategy. For example, our Mechanical Car 243 program consists of one training course and one OJT checklist. It still requires regulated employers to review the content to make sure it is relevant to their operation but it also creates a baseline for railroads and contractors to start with.

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 

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