For years, many industrial facilities in CSX territory operated under an informal understanding: CSX would inspect private track as part of their ongoing presence at the facility. That arrangement is over.
CSX has formally ended its practice of inspecting private industrial tracks. The policy change is significant not because it alters what the FRA requires — the regulatory framework hasn't changed — but because it removes a layer of oversight that many facility operators had come to rely on without fully recognizing they were doing so.
What changed and why it matters
Under the prior arrangement, CSX track personnel would walk private sidings and leads during car spot and pull operations, flagging obvious deficiencies. This wasn't a formal compliance inspection — it was incidental observation by people who knew what to look for. But it served as a rough safety backstop for facilities that weren't running their own inspection programs.
That backstop is gone. The practical effect is that facilities in CSX territory that were relying, even partially, on the carrier to surface track issues now have no external eyes on their private infrastructure unless they've hired an independent inspector.
"FRA Part 213 standards apply the moment a Class I carrier operates over your track. That obligation has always rested with the facility owner. CSX's policy change simply makes that fact impossible to ignore."
The regulatory framework hasn't changed
Under 49 CFR Part 213, track that is operated over by a railroad carrier — including a Class I operating over your private siding — is subject to the FRA Track Safety Standards. The obligation to maintain that track in compliant condition rests with the track owner. It has always rested with the track owner.
CSX's inspection of private track was never a regulatory requirement on their part, and their discontinuation of that practice doesn't create any new regulatory exposure. The exposure was always there. What's changed is that the informal mechanism that was quietly managing some of that exposure no longer exists.
The audit risk is real
Class I carriers routinely audit the private industrial tracks they serve. The purpose of these audits is to assess whether the track meets the standards required for the carrier's equipment to operate safely. A facility with documented deficiencies — or worse, no inspection documentation at all — is a candidate for restricted or suspended car delivery.
Service restriction is a serious consequence. For facilities that depend on rail delivery for production inputs or outbound shipments, a restriction that lasts even a few weeks can have significant operational and financial impact. The leverage is entirely with the carrier.
The only reliable defense is documentation. A facility with a current inspection record, completed by an FRA-certified inspector, that shows the track is in compliant condition — or that deficiencies are identified and in remediation — is in a substantially stronger position than one with no documentation.
What to do now
If your facility is in CSX territory and has not had an independent track inspection, the first step is a baseline inspection. A baseline establishes the current condition of every track segment that receives car movements, classified by FRA standard. From that baseline, you'll know exactly what your exposure is and what, if anything, needs to be remediated before a carrier audit.
If your track is in good condition, the baseline becomes the foundation of an ongoing inspection program — typically monthly for active facilities. If there are deficiencies, the baseline gives you a remediation roadmap and the documentation that you're actively addressing them.
The policy change is a useful forcing function. Facilities that have been meaning to formalize their track inspection programs now have a clear reason to do so immediately rather than eventually.
Doerr Street Rail Co provides independent baseline inspections and ongoing monthly programs for industrial facilities across the Southeastern United States. Our inspectors bring decades of Class I experience — including direct familiarity with how carrier audits are conducted. Written reports are delivered within 48 hours.