In investigating the derailment of Amtrak's Auto Train on April 18, 2002, the National Transportation Safety Board (NTSB) reported that an accurate count of persons on the train at the time of the accident was not available at the accident scene. NTSBnoted that emergency response would be improved with accurate count data at the accident scene and issued a Safety Recommendation to the Federal Railroad Administration (FRA) that it develop and implement an accurate passenger and crew accountability system. This report assesses the weaknesses in Amtrak's passenger accounting system, the costs of improving it, and the potential safety and business benefits of an improved system. It finds that while technically feasible, the recommendation is impractical given Amtrak's business model and would not provide the desired safety benefits. It also identifies alternativeimprovements to Amtrak's passenger accounting system that can be the basis for future cost-effective Amtrak initiatives