What FRA Part 243 Records Do Railroads & Contractors Need to Maintain?

Meeting FRA Part 243 requirements means more than completing training—it means documenting it clearly and keeping proof you’re in compliance.

Whether you're a railroad or contractor, your ability to show you’ve met the training requirements depends on the records you keep.

Here’s what you need to have on hand to stay compliant with 49 CFR Part 243:

Proof of Employee Qualification Status 

For every safety-related railroad employee—including contractors—you must maintain a record of their qualification status.

Each record should include:

• Employee name
• Occupational category or subcategory the employee is qualified for
• All training course title(s) and date(s) completed
• If applicable, transcripts or records from an FRA-approved training provider (i.e., training company, learning institution)
• For on-the-job training (OJT):
  • Unique name and identifier of the OJT component
  • Completion date
  • Name of the designated instructor who determined the employee successfully completed all OJT requirements
  • Date the employee’s status was deemed qualified
• Training record documentation from previous employers, if employee’s qualification is transferred
• Records of refresher training
• Any additional items required under 243

Retention period: Keep these records for at least 6 years after the employee leaves your company. Records must be accessible at your system headquarters.

Read the full regulation text here: Go to FRA.gov

Periodic Oversight Documentation 

You’re also required to document how you’re demonstrating compliance on an ongoing basis. This includes:

• Your written periodic oversight plan
• Inspection or tests results completed for periodic oversight

Retention period: Keep these records for a minimum of 3 years.

Read our blog on 243 periodic oversight requirements: Open article

Read the full periodic oversight regulation. Go to FRA.gov

Designation of Existing Employees (also known as grandfathering-in) 

Most regulated employers were required to submit their initial 243 training programs by May 1, 2021. To “grandfather in” current employees, you must have:

• Created a list of designated employees by occupational category
• Or recorded these designations in your learning management system by January 1, 2022

Read our blog on grandfathering employees under 243: Open article

Designated Instructor List 

The regulation requires formal training to be delivered by a designated instructor—someone who’s qualified in both subject matter and delivery.

To stay organized, keep a list of your designated instructors by job category and/or training program. You’ll need to be able to show that each person meets the criteria under §243.5.

“Designated instructor” means someone named by an employer or training provider who has proven knowledge of the topic and, where needed, has relevant experience to provide effective instruction.

Here is the official FRA definition:

Designated instructor means a person designated as such by an employer, training organization, or learning institution, who has demonstrated, pursuant to the training program submitted by the employer, training organization, or learning institution, an adequate knowledge of the subject matter under instruction and, where applicable, has the necessary experience to effectively provide formal training of the subject matter.

See other § 243.5 definitions here

Railroad-Maintained List of Contractors

If you're a railroad using contractors for safety-sensitive work, you must keep a current list of all contractors unless you:

1. Personally qualify each contractor’s safety-related employees, and
2. Maintain their training records yourself

Your contractor list must also include:

• The contractor’s full business name
• Primary business and email address
• Primary phone number

This requirement applies only to railroads, not contractors.

Read the full contractor listing requirements text. Go to FRA.gov

Still Working Through Your 243 Program?

If you’re not sure whether your records fully compliant with FRA—we can help. Spark TS works with Class I, short line, and regional railroads, as well as contractors, to simplify Part 243 from start to finish.

Whether you need a recordkeeping system, help submitting to the FRA, or just clarity on your training program, we are here to make it manageable.

Need a Checklist?

Rail Tasker’s checklist module makes it easy to:

• Track every record required under FRA 243
• Store qualification and OJT documentation securely
• Assign oversight activities
• Keep your records inspection-ready year-round

📩 Reach out at info@sparkts.net or request a demo of Rail Tasker to see how we can support your compliance efforts.