Re: Rotary OM

To add a little more fuel to the fire.
Earl is correct. The rotaries (and other work equipment) are not considered motive power and the boilers consequently do not fall under FRA justisdicton.
But how could someone suggest that the RR does not come under FRA?
So, to go over quickly the FRA reasons for inclusion:
While maybe not connected to the general railroad system, it has a number of other areas that bring into a compliance requirement.
1. Crosses public highways.
2. Crosses state lines
3. Crosses waterways.
(1 & 2 are the biggies.)
4. Hauling any freight (interstate or local) over state lines and transporting the public for money.
5. The good thing is, the "historic train" exempts these type operations from more stringent requirements.
There is more to this, but you get the idea.
This was a big fight a few years ago when it came down to who had was be under the FRA jurisdiction and who was not.
But, enough said on that.
Chris