Thanks Jerry! I intended to say also that the record keeping is not only for the FRA, but it provides a way for the operator to track saftey issues, though in an operation as small as ours, some of it seems silly such as the monthly accident report with it's notorized copies along with electronic reporting.
Thanks PRSL for your response to clarify your position. I think that at least in our case being under FRA is an advantage with regard to our steam boilers. Our state's boiler inspection protocols were not a good fit with a rr's locomotive boilers. One thing in particular was the requirement under state jurisdiction that we use ASME saftey valves. The products we had used under state jurisdiction that had the ASME designation were far more trouble prone than the Lunkenheimer locomotive valves we have on each engine as the higher set valve with Consolidated copies from Strassburg as the lower set safties.
None the less PRSL, I do see your point as far as agencies overstepping their bounds.