Above I was quoting from Part 240. Below is additional information from FRA. You can see here FRA is saying that if you are using a Brandt to handle revenue cars you need a certified engineer. But if you examine various rules for locomotives you'll see that the machines don't comply with many requirements of a locomotive including safety glazing, periodic imspections, toilets, safety appliances, step height, etc etc. When the rule was developed you can imagine that BMWED and BLET were not completely on the same page since this machine spans both their employee groups. Bottom line; you can't use these machines to move revenue equipment - even to the extent of moving a sand car from a yard to a nearby locomotive servicing facility.
Quote:FRAQ. 53 - Do I need a certified engineer to move a dual-purpose vehicle 240.104(a)(2)?
Answer: Maybe. The answer depends on how the dual-purpose vehicle is being used. If you are using the dual-purpose vehicle to perform routine switching of cars in revenue service, then you need a certified engineer to operate it. You do not need a certified engineer to operate a dual-purpose vehicle if the vehicle is:
1. Being operated in conjunction with roadway maintenance and related maintenance of way functions, including traveling to and from the work site;
2. Moving under the authority of railroad operating rules designated for the movement of roadway maintenance equipment that ensure the protection of such equipment from train movements; and
3. Being operated by an individual trained and qualified in accordance with Sections 214.341, 214.343, and 214.355 (Roadway Worker Protection Rules)
FRA Q & A