Global freight supply chains are complex systems composed of steamship lines; truckers; railroads; ports; drayage providers; owners of truck chassis, shipping containers and warehouses; manufacturers; wholesalers and retailers of goods. All stakeholders must do their part to maintain a consistent flow of freight at every step of the process to avoid bottlenecks and ensure that freight is delivered safely, efficiently and when expected.

A complex web of issues impacts every phase of the supply network — from sourcing to manufacturing to last-mile delivery. For railroads, the biggest challenge today is the nationwide challenge to recruit and retain qualified employees. Many industries — including railroads’ largest competitor, the trucking industry — are having difficulty hiring and retaining employees to meet the surge in demand. As the STB recognizes, “carriers have reported hiring difficulties — difficulties that are not restricted to the rail industry.” Additional challenges include:

• Global manufacturing capability, demand and consumption patterns have bucked historical trends. The COVID-19 pandemic continues affect manufacturing worldwide, even as consumer demand for goods — including via e-commerce — remains high. Ports, trucking, railroading, warehousing and distribution centers continue to adapt to these unpredictable changes.

• Unexpected increases in customer car orders hurt dwell time and network velocity. When demand grows, and rail capacity is in short supply, some customers increase their railcar orders beyond what they actually need. The influx of additional cars into an already congested system reduces the fluidity of the entire network.

• Other external events are exacerbating service issues. Recent extreme weather events, rising inflation, and the Russia-Ukraine War add further uncertainty to supply chains and upending global markets, including agriculture (Russia and Ukraine together account for 40% of global wheat exports), fertilizer and energy.

Freight railroads are an essential link in the nation’s supply chain, working around the clock, day-in and day-out to improve their service, safety and sustainability. Today, they employ a well-paid workforce and are actively recruiting and training new workers. They provide environmentally responsible transportation solutions and are developing and testing new technologies to usher in an even lower carbon future. And they invest billions of dollars to maintain and modernize their top-rated infrastructure.

While there is never a good time to implement ill-advised regulations on a transportation network critical to our economy, doing so when supply chains are already facing severe challenges would be especially unwise. There are many examples of federal regulators either implementing or considering rail regulations that would cause unintended consequences or harm the efficiency and quality of rail service.

Forced switching is one of the more problematic proposed regulations. Under this rule from the Surface Transportation Board, railroads could be forced to turn over traffic to competitors. This bad policy would slow rail operations and hurt shippers, consumers, the environment and the economy. Supply chain impacts must be top-of-mind, and Congress and the administration should proceed cautiously when considering new requirements or regulations on the industry.