The men, aged 60 and 64, from the Tebay area, were arrested on suspicion of manslaughter. Both have been released on police bail pending further enquiries until 26 March, 2008.
Both men are Network Rail employees.
A 46 year old man from Preston, arrested in connection with the incident in July 2007, remains on police bail to return to BTP on 26 March 2008.
The arrest on suspicion of manslaughter relates to the death of Margaret Masson, aged 84 who died following the disaster.
The official report into the disaster released last month blamed lapses in Network Rail’s track maintenance and supervision regime.
The Rail Industry Report revealed a catalogue of failures.
These culminated in an incomplete inspection of the Lambrigg 2b facing points on 18 February 2006 – just five days before the accident which left one passenger dead and 22 injured.
The report says that the patroller who last inspected the track, finished work early on the day of the incomplete inspection. If the inspection had been completed as planned, the report concludes, it could have revealed the crucial broken stretcher bar, and prevented the fatal derailment.