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The 49 CFR 231.17.e, (e) doesn't differentiate between LED and bulbs: 49 CFR 231.17.e, "(e) Handrails and steps for headlights. (1) Locomotives having headlights which cannot be safely and conveniently reached from pilot-beam or steam chests shall be equipped with secure handrails and steps suitable for the use of men in getting to and from such headlights. This problem was solved very late, waiver request of mid May 2017, so it may be the reason for the late test clearance by FRA. The changed handrails next to the steps to the access doors led to a non-compliance with the specification. At least there was a delay because of non-compliance with 49 CFR 231. Regards, Volker
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