For rail, the FRA does not require the U.S. carriers to develop an SMS. They are working towards something called a risk reduction program that they are trying to develop. Just to clarify it, in the rail mode, before the amendments in the Railway Safety Act came into force on May 1, we had no authority to impose AMPs or to require rail operating certificates. Now we've had that authority since May 1, and we're currently developing a regulation that hopefully will come into force by the end of the summer.
On November 25th, 2013. See this statement in context.