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:
It is just too much information. There is no easy way to determine what information is required and what is not applicable to a specific situation. With so much information to look at, it is easy to get overwhelmed.
It focuses on content versus application. Similar to the first point, it is easy for FRA or training content providers to list content or requirement by CFR Part. This leaves the hard part of figuring out how to apply this information to railroads and contractors. To be fair, the FRA's OJT Matrix attempts to do this but the information is in a format that is nearly impossible to filter and organize.
It is oversimplified. When information is formated this way, it makes the appearance that all railroaders need the same type of training for each CFR Part. In reality, we all know that the rigor, scope, and type of training will vary by job duty. For example, on-the-job training should be required if the employee is going to perform a safety-related task; however, another safety-related employee may not perform that task but need some level of training on its requirement. Or, if there is a model program from CFR Part 218, it leaves it up to the person adopting the program to modify the portions that are not applicable.
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:
It is easier to make decisions on what is required when organizing information by the real-life application.
It creates a long-term strategy that focuses on what is needed and avoids training on unrelated topics.
It filters out all the noise of unrelated information.
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 firstname.lastname@example.org