How much do we need to spend on our plant track to keep it safe?
Seven questions for anyone running his own locomotives on his own track.
The question this Read asksIf the serving railroad refuses our track for thirty days, how many years of our rail maintenance budget does that cost?
Exposure Read 7 · The Plant Railroad
If your facility runs its own power — a switcher, a trackmobile, a locomotive crane — over its own track, then you are not a company with a siding. You are operating a railroad, and almost nothing in your management system is built to know that.
Your maintenance system was designed for process equipment. Your training system was designed for process operators. Your safety system was designed for a factory. A locomotive is none of those things. It is a heavy machine with an air brake system, a traction system and a securement problem, operated in most plants by production employees who were shown how to do it by the man who had the job before them. That arrangement runs for years without incident, which is precisely what makes it invisible.
The second fact is the one that closes plants. Your rail service does not depend on your track being safe. It depends on your track being acceptable to somebody else. When the serving carrier’s crew comes inside your gate to spot and pull, they come under their employer’s rules, their employer’s safety department, and their employer’s willingness to put a locomotive and two men on property it does not control and cannot inspect on its own schedule.
The standard governing the track the carrier uses is not the one in your capital plan. It is the federal track standard, which reaches that track inside your fence and holds you liable as its owner (49 CFR 213.3(b)(1) and 213.5(a); 49 CFR Part 209, App. A), and above it the serving carrier’s judgment — and most plants have never asked what either is. Track inside a plant that no general system railroad operates over, where the plant moves cars only for its own industrial processes, is outside the federal track standards, which call such an installation a plant railroad (49 CFR 213.3(b)(1)); a plant that switches cars for others does not qualify. The locomotive standards do not apply to a railroad that operates only on such track (49 CFR 229.3(b)(1)). The serving carrier’s duty is to serve on reasonable request (49 U.S.C. 11101(a)), and a complaint runs to the Surface Transportation Board (49 U.S.C. 11701(b)).
Each rule cited here was read in its current published text on 13 NOV 2026, at the eCFR (current to 10 NOV 2026). The law changes after that date; read the current text before relying on any of it.
Run them yourself.
The seven questions below take an afternoon, your own records and a walk. None of them requires a railroad background.
Who is qualified to operate your power — and who says so, in writing?
Not trained. Qualified, against a written standard, with a dated record and a re-qualification interval: operating the locomotive, air brake and hand brake, shoving movements and point protection, securing equipment, and what to do when something goes wrong. If the honest answer is that the last man showed him, you do not have a program. You have a custom — and a custom cannot be produced after an incident.
Who maintains the locomotive, to what inspection standard, and where is the log?
Daily inspection, periodic inspection, air brake testing, wheels, sanders, lights, horn, traction, leaks. Plant power is very often maintained on a when-it-stops basis by the people who maintain everything else on the site.
How do you secure standing equipment — and has anybody ever tested it loaded?
Hand brakes applied and verified, chocks, derails, and the grade you actually have rather than the grade on the site plan. A cut of loaded cars that rolls is the worst thing available on a plant railroad
What standard does your serving carrier require before it will come in — and when did you last ask?
In writing, from the carrier: clearances, track condition, derails and protection, walkways, vegetation, lighting, and what notice they owe you before they stop entering. Most facilities have never asked, and receive the answer for the first time in the form of a refusal — at which point the conversation is about restoring service rather than about maintaining it.
What is the condition of the track their crew actually rides and walks — measured against that standard?
Not your track in general. The specific track their locomotive occupies and their men walk beside: gauge, surface, ties, switch points, drainage, clearances, footing. The carrier is not evaluating whether your track works. It is evaluating whether its employee can get hurt on your property, and those are very different tests.
Do you have a written operating practice — and does it describe what happens at two in the morning?
How movement is authorized inside the plant, how shoving movements are protected, radio discipline, and the exact point at which authority passes between your people and the carrier’s. The handoff is where plant railroad incidents cluster, for one reason: both crews believed the other one had it.
What does a carrier refusal cost you per day, and has anyone computed it?
Not a derailment — a refusal. The carrier declines to enter until the track is brought up. Production stopped or slowed, inventory, demurrage on cars you cannot place, trucking at spot rates, contracts missed. Price one week, then compare it to the cost of maintaining to a standard you have never requested.
Questions 01, 02, 03 and 06 are about whether you are operating a railroad properly. Questions 04, 05 and 07 are about whether you will still have a connection. The second set is the one with an outside party holding the decision.
How many years of rail maintenance one thirty-day refusal spends.
Set the thirty-day refusal figure against your annual rail maintenance spend. Divide the first by the second: that is how many years of maintenance one refusal spends
What arrives.
The carrier’s standard, obtained and written down
What your serving railroad actually requires before it will enter, in writing, from them — with your property assessed against it, item by item, and the gaps ranked by whether they threaten service or merely cost money. This single document ends more internal disputes than anything else in the engagement.
A qualification and inspection baseline you can produce
Who operates, what they are qualified to do, against what written standard, on what date, with what re-qualification interval — and the same for the locomotive: what gets inspected, by whom, how often, logged where. Built from what your people already do, not imposed over it.
The track walked and written up against a real target
Every defect located and classed by what it will do rather than how it looks, with drainage, switch points and clearances treated first because that is the order in which they cost you. Priced to do this year and priced to do in three.
A written operating practice that matches the property
Movement, protection of shoving moves, securement by location and grade, radio, and the handoff with the carrier’s crew stated explicitly. Short enough to be read and specific enough to be followed at two in the morning, which is the only test that matters.
And what comes after, if you want it
Three things are ongoing rather than one-time: a locomotive servicing and inspection program run to a real standard; qualification and re-qualification of your operators; and track maintained to the standard your carrier accepts, so the connection is never the thing at risk. None of that is set here. It is set after somebody has seen the property.
The seven questions above are the test of the firm that wrote them. Run them, and judge the firm by what they find.
Questions 01, 03, 06 and 07 can be answered by your own people this week, and they are yours to run. Question 04 requires nothing but a letter to your serving carrier.
If the answers are worse than you expected — or if what you need is somebody who has sat on both sides of that gate, as the carrier coming in and as the operation being come into — write and say what you found.
Our bench of career railroaders brings better than 160 years of combined field experience. Nobody we send learns railroading on your property. That is a standard, not a résumé.
Write and say what you found.
Write and say what you found, or call 928.605.7984 and say it. Not an impression — what the seven returned on your own property: your score, and which one you could not answer. The one you could not answer is the finding. It is worth more than anything this firm could tell you before seeing it, and on most plants it is the whole matter.
You will have a reply within one business day, from the principal and not from a form. Writing puts you on no list. If what comes back says you have no problem, you will be told so. What comes back sets the next stage, or the work stops there. The full Exposure Read, with its worksheet, comes from the same address.
This page is general information about railroad practice and the rules it cites, as they read on the date shown. It is not legal, engineering or financial advice, it does not replace counsel or an inspection of your property, and reading it does not engage SteelWheels.Co.
solutions@steelwheels.co · 928.605.7984 · What happens when you write back