Two recent freight train derailments closing portions of Washington's Metrorail system raise safety concerns that go well beyond this community. While the shutdown of Metro places a spotlight on that section of track, the whole story is that inadequate rail safety laws coupled with haphazard enforcement by the Federal Railroad Administration have resulted in a potentially dangerous situation wherever freight trains are operating.

Following eight derailments this year alone, the FRA has just announced a decision to conduct a safety assessment of CSX's Baltimore division. To criticize the FRA for doing "too little too late" does not begin to deal with the real source of the problem, a combination of public policy and regulatory deficiencies.

In the public policy area, despite the fact that there are 10 separate acts of Congress that directly address rail safety, there remain numerous omissions or conflicting standards in current law. Congress is working on rail safety legislation this session, but in its present form the legislation is inconsistent in raising penalties for safety violations -- penalties that need to be increased for hazardous materials, car inspection and other areas.

But despite shortcomings in the law, there is no excuse for the manner in which the FRA has allowed a dangerously lax attitude toward safety to develop among the carriers. Specifically, the FRA has eliminated practically all incentives for the carriers to comply with safety regulations by adopting a policy of assessing penalties only if a carrier fails to correct a problem in a timely fashion once a problem is identified.

Rather than preventing problems from occurring, for which there is now no incentive, the carriers tend to correct problems as the FRA inspectors uncover them. As a General Accounting Office report has pointed out, this problem is compounded by the fact that it would take some FRA inspectors three to five years to cover their territories due to serious manpower shortages.

The FRA is in need of a massive reorganization to protect railroad workers and the public safety from what remains one of America's most dangerous work environments. GEOFFREY N. ZEH President Brotherhood of Maintenance of Way Employees Detroit

In "Another Derailment" {editorial, Sept. 8}, The Post's recommended "solution" provides for the prohibition of CSX trains on a section of track for 18 hours during the running time of the Metro trains. This would be great for Metro but undoubtedly unacceptable to CSX because of the extremely small window of operation for its daily trains.

Why not arrange for CSX and Metro to agree to have the Metro trains wait (out of harm's way) for the 3 to 5 minutes while each of the CSX trains scoots by without schedule disruption? This sort of arrangement could be readily acceptable to CSX, and it could motivate CSX to place into operation the other safety measures such as increasing the strength of the safety median wall between CSX tracks and Metro tracks. This may be a more acceptable solution. SAM P. TRIFFY Alexandria