Understanding OJT vs. Efficiency Testing Under FRA Regulations

Railroad compliance can be tricky, especially when distinguishing between On-the-Job Training (OJT) under 49 CFR Part 243 and efficiency testing under Part 217. Here’s what you need to know:

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What Part 217 Efficiency Testing Covers

Part 217 focuses on periodic operational testing, or inspections to verify that employees are following rules and timetables. This is a post-qualification check, ensuring that employees are performing compliant actions once certified.

What Part 243 OJT Requires

Part 243 mandates structured and hands-on training before employees are qualified to perform safety sensitive tasks. This training must be coached by a qualified instructor, with real-world guidance and supervision.

The Crucial Difference

Per FRA guidance, efficiency testing cannot substitute for Part 243’s OJT requirement. They serve different purposes in a compliant training program.

Why This Difference Matters:

Confusing these two can leave your company out of compliance and your team undertrained. A well-designed Part 243 OJT program prepares employees, while Part 217 checks ensure sustained adherence.

Next Steps for Rail Operators:

• Review your training protocols: Do you have both initial OJT and post-qualification testing?

• Ensure your OJT is instructor-led and conducted before employees start their duties.

• Use Part 217 testing to monitor job performance—but not as a training substitute. Review your training protocols: Do you have both initial OJT and post-qualification testing?

• Ensure your OJT is instructor-led and conducted before employees start their duties.

• Use Part 217 testing to monitor job performance—but not as a training substitute.

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Confused with building a compliant OJT program that meets both training and oversight requirements?

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