Is this Plan subject to 411 accrual rules?

[Gary]

I reviewed a Plan that is in the railroad industry (at least I understand it to be that way). They are publicly traded and file 5500's. So it appears to be an ERISA Plan. For some employees they have an offset based on a railroad act benefit and for certain other employees the SS offset applies. I am trying to determine if this Plan is subject to 411 accrual rules. It appears that it would be. Anyone else have comments?

Gary