The FRA is empowered to waive the requirement that crews covered by the Hours of Service Act have 48 hours off duty after working six consecutive days. The FRA may also waive the requirement that Hours of Service employees work no more than 276 hours in any calendar month. Before granting relief, the FRA must find that it is "in the public interest and will not affect safety adversely." Generally, waivers are limited to railroads having fewer than 15 Hours of Service workers - but, in special circumstances, waivers have been granted to Class 1 railroads like BNSF and CN. If the railroad seeking the waiver is organized, the union covering the craft must concur.
My suggestion is that C&TS petition the FRA for relief -either on its own - or as a part of a joint effort with other tourist railroads. The American Shortline & Regional Railroad Association (ASLRRA) has already petitioned the FRA on behalf of a number of its smaller members.