Amtrak could be forced to reduce train service after the end-of-the-year travel crunch because some workers have not complied with a mandate to be fully vaccinated in January.

About 6% of the railroad’s workforce could be fired for failure to show proof of vaccination by a Jan. 4 deadline, according to an internal company memo and interviews with labor and industry leaders.

The terminations could harm Amtrak’s recovery from the pandemic slump after recent progress in restoring service and rebuilding ridership that plummeted by 97%. It could also exacerbate staffing problems amid a national worker shortage that Amtrak leaders say has hampered the railroad’s ability to return to pre-pandemic schedules.

Any service reductions – which would come weeks after Congress approved $66 billion in new investment for rail – could dampen Amtrak’s momentum, observers say, noting that it could hurt rider confidence in the system and ignite new scrutiny among congressional leaders.

The railroad is expected to publish a revised service schedule by mid-December to reflect possible cuts, according to Amtrak. In a memo to workers last month, chief executive William J. Flynn said the railroad is preparing “for the possibility that some number of employees will choose not to get vaccinated and will therefore be leaving the company, which could necessitate some temporary reductions of Amtrak service.”

The company said in the memo that 88.2% of its roughly 17,000 workers had been vaccinated late last month, and projected an additional 6% were on track to comply this month. Amtrak said Friday it expects the number “to be slightly higher” by the January deadline.

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Amtrak already has pushed back disciplinary action against noncompliant workers until after the busy holiday travel season, a timeline that railroad officials say is in line with new government guidelines for federal agencies. Although Amtrak operates as a private company, it was created by Congress, reports to the government and relies on federal subsidies.

The federal vaccine policy is being challenged in court by labor unions, which have pushed for the return of a more flexible policy that allows a testing option for those unwilling to be vaccinated.

It is unclear which routes could face reductions. Amtrak has not said whether unvaccinated workers are concentrated in any particular region of the country. Some industry and labor leaders say rural areas would be most likely to suffer, in part because vaccination rates are lower and crews are smaller. Replacing key workers – such as locomotive engineers or train conductors – could prove difficult as safety protocols call for trained workers who already are familiar with routes to run trains.

Effects on the Northeast Corridor could be less disruptive because the busy Washington, D.C.-to-Boston route is served by multiple trains and lines daily, and travel demand has not fully rebounded. The timing also coincides with a slower post-holiday travel period. The Northeast, with its higher vaccination rates, is also home to a large share of Amtrak’s workers. Still, any reduction in personnel outside the Northeast and West Coast could take a toll on the cross-country, overnight routes that run once a day.

Vaccination rates vary by region, the company said Friday, noting that it is assessing impacts to “make decisions as to which routes should have revised schedules.”

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“While this has been an incredibly difficult decision, we must remain vigilant in our commitment to keep employees and customers safe,” the company said of possible service cuts. “We remain confident that we will not only restore service but will eventually, with the help of federal investment, expand our service to new communities across the country.”

Jim Mathews, executive director of the Rail Passengers Association, said some long-distance routes could temporarily go from daily service to operating three times a week.

“That would be really upsetting, and frankly, it would be upsetting to the members of Congress who wrote Amtrak checks with the idea that that would not have to happen,” he said.

Some labor unions are hoping a suit filed in federal court in Chicago could avert terminations and service reductions. The Brotherhood of Locomotive Engineers and Trainmen (BLET) and the Transportation Division of the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART-TD) earlier this month filed suit against Amtrak, calling the policy “unlawful.” The unions say Amtrak has no authority to enforce a vaccination mandate among employees, and that doing so without negotiating with unions is a violation of federal labor law.

“We have several objections to Amtrak’s unilateral implementation of its policies mandating them and illegally dealing directly with its represented employees,” BLET National President Dennis Pierce and SMART-TD President Jeremy Ferguson said in a joint statement. They called the lawsuit “an effort to stop Amtrak’s lawlessness in its tracks.”

Amtrak said it is reviewing the filing and declined to comment.

Amtrak is following the Biden administration’s vaccine mandate for federal workers, which officials say will save lives by encouraging more people to get vaccinated. The railroad is requiring proof of at least one vaccine dose by Dec. 8, and in its Nov. 22 memo, the company said workers who don’t submit proof of two vaccines by Jan. 4 “will be considered insubordinate” with “the termination process to begin immediately.”