The AASM submitted comments to the Federal Railroad Administration on the proposed modification of duty hours for train employees who provide commuter and intercity rail passenger transportation. The AASM cautioned that hours of duty limitations also are necessary for other train employees; fatigue from inadequate sleep can affect the performance of personnel who provide critical maintenance and oversight, which also increases the risk of accidents. The AASM also advised that the regulations should be more specific in recommending that train employees have at least eight hours of off-duty “sleep time.”