Has anyone ever had to put a blue card on a Trackmobile? Or found out that they don't need one? Ever had to deal with the F.R.A. on using one in your operation?

If you read the FRA locomotive inspection requirements I think you will find a Trackmobile is not legal to use as a locomotive, so no blue card would be needed.

This same question came to mind recently when I observed ballasting operations on the Southwest Pennsylvania around Youngwood, PA using a string of Wheeling & Lake Erie hoppers propelled by a big Trackmobile. In one case this combination was operating over a public crossing around the same time that an SWP freight occupied an adjacent track. Track machines such as tampers don't need a blue card, but when something that works like a locomotive acts like a locomotive and moves cars just as a locomotive might, it sure causes you to wonder.

From FRA compliance manual Section 8-229.5
Periodically, FRA receives inquiries about equipment requirements for self-propelled vehicles used to haul revenue freight on the main line.
These vehicles include those built by Trackmobile Inc., Shuttle Wagon, Mitchell Equipment Corporation and Brandt RoadRailer®. Self-propelled vehicles are used in a variety of railroad functions. When self-propelled vehicles are used only in the performance of typical maintenance-of-way functions, or if they are used to move cars or equipment within the confines of repair facilities, they are to be considered specialized maintenance equipment and are exempt from many FRA regulations. When a self-propelled vehicle is used to move freight over the
railroad, outside the limits established for maintenance-of-way operations and repair facilities, it will be considered a locomotive and must comply with applicable regulations. Even though these vehicles do not resemble a standard locomotive, the purpose for which they are being used requires compliance with 49 CFR parts 223, 229, 231, and 232. The self-propelled vehicles are unique in construction, appearance, and use. Many of these vehicles currently being used have already been modified by the manufacturers (as closely as construction would permit) to bring them into compliance with Federal regulations. FRA acknowledges that this equipment has a place in a well-rounded rail transportation system. In an effort to recognize the unique characteristics of these vehicles, FRA inspectors should exercise enforcement discretion and good judgment in analyzing an operation where selfpropelled vehicles are used for train movements. Items deemed to be safety-related, that cannot meet specified requirements, will have to be addressed through the waiver process. The following specifications should be used by inspectors for enforcement guidance:
1. The vehicle glazing material must comply with part 223.
2. Each self-propelled vehicle shall be inspected each calendar day when used, and an inspection report and record shall be completed as described in section 229.21.
3. Each self-propelled vehicle shall receive a periodic inspection as described in section 229.23, and all pertinent data is to be entered on an FRA Form F6180.49A, Locomotive Inspection and Repair Report, which shall be displayed under a transparent cover in a conspicuous place in the cab of the vehicle.
4. The vehicle’s air brake equipment must be cleaned and tested as often as conditions require, but not less frequently than required in sections 229.25, 229.27, and 229.29.
5. The main air reservoir must comply with section 229.31 regarding either hammer and hydrostatic testing or pre-drilling of the reservoir.
6. The vehicle must meet general safety requirements of sections 229.41, 229.43, and 229.45.
7. Fuel safety cut-off devices must follow Section 229.93.
8. The vehicle must have a speed indicator if it is operated at a speed that exceeds 20 mph according to section 229.117.
9. Interior cab noise must comply with section 229.121.
10. Vehicle headlights must be fully functional; and, if operated at speeds in excess of 20 mph over one or more public highway-rail grade crossings, must comply with auxiliary light requirements according to section 229.125.
11. The vehicle must be equipped with a horn according to section 229.129.
12. If operated at speeds in excess of 30 mph while hauling cars, the vehicle must be equipped with working event recorder in compliance with section 229.135.
13. Switching steps as defined in section 231.30.
14. Four horizontal handholds shall be secured to the front and back ends of the vehicle, and shall be secured by bolts or other acceptable mechanical fastener (see Section 231.30).
15. The vehicle should have vertical handholds painted in contrasting colors and secured by bolts or other acceptable fasteners in compliance with section 231.30.
16. The vehicle must be equipped with automatic couplers, to prevent the necessity of someone going between the vehicle and car for the purpose of coupling or uncoupling in compliance with section 231.30.
17. If conditions warrant, a two-way end-of-train device must be used in compliance with sections 232.401–232.409.
18. As with any train movement, the vehicle must be equipped with a brake system that permits the operator to apply and release the brakes on cars being hauled. The brake equipment must also be arranged so that proper air brake leakage tests can be conducted as applicable in compliance with sections 232.12 and 232.13. (MP&E 98-71.)
Despite the fact that the Burro Crane is excluded from the definition of “locomotive” under §229.5(I) of the Locomotive Safety Standards as a piece of specialized maintenance equipment, and is not subject to those Standards, the Burro Crane is nevertheless subject to the statutory
requirements of the Locomotive Inspection Act, in particular, the requirement that it is safe. In the preamble to the final locomotive rules, FRA explicitly recognizes the applicability of the Act by stating that “FRA will continue to implement the basic statutory safety requirements with respect to such work equipment by using the Special Notice when appropriate.” 45 FR 21093.
(MP&E 98-25.)

Mike Tillger