Thanks Jim for the informative follow up. But I am correct on the FRA/ICC jurisdiction over type of couplers required used-per law. Confirmed by FRA Inspection office. The AAR is not law, and FRA rules say that MCB coupler SHALL be used. The ICC did require that coupler not be painted and location of operation levers as you offered.
How do you guess they operated train in the 1920s with Miller Hooks on passenger runs and next run was a freight train with MCB? They linked them with link and pin and it was legal. The unions took it to court and lost shortly after the Safety Appliance Act went into effect. The Judge ruled that the Act only applied to Cars of Commerce. It was not till 10/30/1911 that at Atlanta District Supreme Court (Sou.RR versus US) that all car of inter and intra state operation was covered. That Judge acknowledge that he did not have the jurisdiction but for safety reason he ordered all railroad to only use full Safety Appliance applicable cars in all movements. It was not appealed. Up to that point, many railroad used non-compliance cars on local moves, and they did not cross state lines. RGS would route cars via Ridgway-Gunnison-Salida, rather than Durango-Chama as that crossed state lines. The local newspapers had a fit deriding the RGS for using unsafe car and warning the inspectors will fine them soon.
And again, the Law had it limits and did not cover private railroad opeations. It only covered what it had jurisdiction to cover. Some people try to assume too much these days.