When a railroad contracts TCS to perform locomotive engineer certification administration, TCS manages the entire package. That is how we are unique in this field – TCS is a turn-key, one-stop service company for engineer training and certification.
Since 1991, TCS has been among the industry leaders in compliance of 49 CFR Part 240 regulations pertaining to Qualifications for Locomotive Engineers. TCS guided and educated dozens of railroads by writing, submitting and administering their Part 240 Submissions to the FRA. TCS officials have made numerous trips to Washington, D.C. to advise, testify and assist several government panels and departments in fine-tuning the existing regulations.
TCS acts as a liaison between the FRA and its client railroads for all matters pertaining to the regulations governing railroads in the United States. TCS has extensive knowledge of the certification regulations and stays abreast of any changes so as to keep clients informed on a timely basis. If an audit is conducted by the FRA on a TCS client, TCS supplies all required documentation and represents the client to a satisfactory completion of the audit.
TCS’ top management participates on FRA committees, conventions and has assisted the FRA in group presentations. TCS has assisted the FRA in verbiage on several changes to the existing certification regulation. TCS’ forms, submissions, training programs, operating plans, reports, etc. are on file with the top regulators of the FRA in Washington, D.C., and all meet or exceed the standards and criteria demanded of the governing agencies.
The certification regulations were designed to set standards for engineers and require that each railroad adopt its own program for determining qualifications. These regulations mandated various requirements including the following:
1.) Selection of Designated Supervisor of Engineers
2.) Selection of Class of Service of Engineers
3.) Evaluation of the Safety Conduct of Engineers
4.) Evaluation of Hearing and Visual Acuity of Locomotive Engineers
5.) Initial and continuing education/training programs for Locomotive Engineers
6.) Testing of Engineers
7.) Operational Monitoring of Engineers
8.) Administration of the Certification Program
While somewhat complicated, these safety-centered regulations were welcomed in the railroad industry.
TCS is the only non-railroad affiliated training company in the United States that offers both locomotive engineer certification administration and locomotive engineer training. This duality results in complete certification of the engineer as a fully trained, promoted and certified locomotive engineer and complies with all federal regulations.
TCS provides all aspects of certification administration. TCS plans submissions for railroad regulation compliance, tailors programs to meet the clients’ needs, and provides all FRA-approved forms and training for engineer certification. TCS then acts as the issuing agent to provide the engineer with the license/certificate required by law to operate trains on the client railroad; and finally, individual engineer and conductor files are maintained for each railroad. All certification documents are maintained in-house by TCS and are available for FRA audit, if necessary.
TCS has the unilateral right and responsibility to issue licenses at the completion of a TCS initial promotion or certification program. Included in a client's 49 CFR Part 240 Qualifications for Locomotive Engineers submission is a declaration stating that TCS is the legal agent for purposes of issuing engineer licenses for that railroad. TCS is distinguished in its non-railroad affiliated status. This allows TCS to act as a non-partial license issuing party for any client railroad.
TCS keeps its clients informed of any changes made by the FRA to the certification regulations and then implements necessary submission amendments on behalf of its clients. Another benefit of TCS is that in the case of joint trackage responsibility, the interchanging of necessary documents with any other railroad becomes hassle free to the client.