Famous author Mallory Ferrell managed the almost impossible by getting a story of an active narrow gauge railroad in between the pages of mega-railroad Trains Magazine. Although only two pages and four photos, it has a location map but no line map. Two of the best photos have caption and giant title overlays which sight-impaired reading machines cannot read.
He makes specific note that Palmetto Brick Company’s railroad uses link-and –pin couplers but don’t imply from his carefully worded reference about the Safety Appliance Act that the brick company is doing anything wrong. I quote: “The cars still use link-and-pin couplers, a type the 1893 Safety Appliance Act required be outlawed by1898, a deadline that was in full effect on common-carrier railroads by 1904.”
The Safety Appliance Act had many exceptions, which prevented a violent interruption of the general operations that were then happening. The first exception was the exclusion of 4-wheel cars. And since the law read: Shall apply to all cars in interstate commerce….” An U.S. Circuit Court directed a jury to rule in favor of the railroad company regarding a link-pin hand injury coupling a tender to a train. This was because the “locomotive and tender was not a car within the meaning of the Act”. This ruling was before June 1902 and was the basic for the split knuckle on engines so they could be linked when necessary to automatic Miller Hook or other types of couplers the cars might have had. Only where a state law required it was there any law naming the Master Car Builder style to be required [NY for example]. Automatic coupler Miller Hooks cars ran into the 1920s linked to locomotives with present day MCB knuckle couplers using a link and pin.
Therefore, the Palmetto Brick Co.’s Plymouth locomotive has never been prevented by any law to operate with the link-and-pin style couplers; and since the cars are all 4-wheel (as is the locomotive) they come under the first exception of the SAA.
Interestingly, further SAA exceptions excluded 8-wheel logging cars if the coupler height was less than 25 inches. That excluded 2’ to 3’ gauge log trains. And Steam Locomotives used exclusively in logging service were also excluded from the SAA. That meant that they did not have to have any air brakes or side step/handholds or automatic couplers. A great example of this exemption was the operation of the Tionesta Valley RR in NW Pennsylvania (into mid-1940s) where log trains ran over common-carrier lines with Heisler locomotives that had only steam brakes, no air brakes on the log flat cars or on the caboose. The TV #111 caboose (without automatic air brakes) is at Kent Furnace, CT, for viewing.