Bret,
In my opinion, the SVRR's engineer training program does not meet the
full FRA requirements for certification of engineers, but the FRA obviously finds the SVRR's program satisfactory under the rules they have imposed on SVRR under the "FRA lite" rules for a tourist operation.
A full FRA certification program requires the railroad to clearly define the program in writing and submit it for approval, formal training (both initial and continuing), a yearly ride along and an unannounced test, minimum hearing and vision requirements, pre-employment and random substance abouse testing, and a few others I failed to list here. Trainmen gnerally fall under the same substance abuse, and operating and air brake rules testing and training. There was a proposal to require anyone performing an air test to have an FRA certification, but I am not sure this was ever implemented.
SVRR's established training and certification program (including the pre-season "safety weekend" and apprenticeship advancement) seems to be sufficient and safe for the present operating conditions. No doubt if there were any incidents, serious concerns or substantial expansion of operations, the FRA would review the SVRR's program.