Comment from Robby Cavazos

I am writing to formally express concerns regarding the increasing use of drones by Trainmasters and MTO personnel within active railroad operating environments. Numerous employees have observed drones being operated during switching operations, around working crews, and in areas where employees are engaged in safety-critical duties. These observations raise serious concerns regarding workplace safety, distraction, and the potential impact on employees performing their assigned responsibilities. Railroad operations require constant situational awareness, effective communication, and unwavering attention to the task at hand. The presence of drones operating overhead or in close proximity to crews can create unnecessary distractions and may interfere with employees’ ability to safely perform their duties. This is especially concerning during switching operations and other activities where hazards are already present and concentration is essential. In addition, questions exist regarding the policies, qualifications, risk assessments, and operating procedures governing the use of drones in these environments. Employees deserve to know: What training and certifications are required for personnel operating drones in railroad operating territories. Whether formal risk assessments have been conducted regarding drone operations around active crews and equipment. What restrictions exist concerning drone proximity to employees, moving equipment, and hazardous work locations. How employee safety and privacy concerns are being addressed. Whether the use of drones has been reviewed by the appropriate safety committees and labor representatives. The purpose of this letter is not to oppose technology or legitimate safety initiatives. Rather, it is to ensure that any use of drones within railroad operations is conducted in a manner that prioritizes employee safety and does not introduce additional hazards into an already demanding work environment. Safety must remain the primary consideration in all operational decisions. Employees should never be placed in a position where surveillance activities create distractions or additional risks while performing safety-sensitive duties. Thank you for your attention to this matter. Respectfully, Rob Cavazos SMART-TD Local Chairman Temple, Texas