In April 1994, the General Code Of Operating Rules was re-written into an 8th GRADE reading level. After checking with the Census Bureau, it was determined that at that time, the average American had an 8th Grade reading level. The previous Edition of the General Code of Operating Rules, (that came out in October 1989 if I remember correctly) was written in an 18th GRADE reading level. It was thought then that this was why it was so hard for new hires to pass a test on it. Now, here 17 years later, there has been so much added to it, that regardless of the reading level, old heads, more less, new hires are barely passing the test, there is just way too much in the book now. I have seen new hires myself that are so scared about loosing their job for failing to remember, more less, comply with a rule, that they end of violating another several rules because of it. It takes years to get to know Operating Rules and now, the way they are changed so often, you might as well forget about memorising them, because as soon as you do, they are changed, again.
As far as Conductor certification, we were also told that, although years away, the railroads truthfully believe that the Conductor will be crossed trained to operate the Locomotives (if he wants to keep a job) so, they might as well get FRA certified now. We also have heard, that FRA wants to have some one more to be held responsible in an incident.