Safety Eligibility Letter CC-115

U.S. Department of Transportation
Federal Highway Administration

1200 New Jersey Ave. S.E.
Washington, D.C. 20590

November 12, 2015

In Reply Refer To: HSST/CC-115

Mr. Brian Smith
Trinity Highway Products, LLC
2525 North Stemmons Freeway
Dallas, Texas  75207

Dear Mr. Smith:

This letter updates eligibility letter CC-115 issued on December 19, 2011 in response to your request for the Federal Highway Administration (FHWA) to review a roadside safety system for eligibility for reimbursement under the Federal-aid highway program

Based on a review of crash test results submitted by the manufacturer certifying the device described herein meets the crashworthiness criteria of the American Association of State Highway and Transportation Officials (AASHTO) “Manual for Assessing Safety Hardware” (MASH), the device is eligible for reimbursement under the Federal-aid highway program. MASH states “Although not a specific factor in assessing test results, integrity of a test vehicle’s fuel tank is a potential concern. It is preferable that the fuel tank remains intact and not be punctured. Damage to or rupture of the fuel tank, oil pan, or other feature that might serve as a surrogate of the fuel tank should be reported.” One test report that accompanied the request for Federal-aid reimbursement eligibility (titled MASH TEST 3-31 on the Vertically Loading Terminal) indicated “A small cut was noted in the fuel tank.” A second test report that accompanied the request (titled MASH TEST 3-35 on the Vertically Loading Terminal) indicated “there was a very small puncture in the gas tank.” Eligibility for reimbursement under the Federal-aid highway program does not establish approval or endorsement by FHWA for any particular purpose or use.

The FHWA, the Department of Transportation, and the United States Government do not endorse products or services and the issuance of a reimbursement eligibility letter is not an endorsement of any product or service

Decision:
The following device was found eligible, with details provided below:

• Trinity SOFT-STOP guardrail terminal.

Requirements
Roadside safety devices should meet the guidelines contained in the American Association of State Highway and Transportation Officials’ Manual for Assessing Safety Hardware. The FHWA memorandum “Identifying Acceptable Highway Safety Features” of July 25, 1997, and the FHWA/AASHTO MASH Implementation Plan provide further guidance on roadside hardware design.

Description and Crash Testing
Your letter of September 3, 2010, enclosed for reference, describes the Trinity SOFT-STOP in detail. Your letter also detailed the crash test matrix that was evaluated for the device. The MASH tests 3-30, 3-31, 3-32, 3-33, 3-34, 3-35, and 3-37) were conducted in reasonably close conformity with the guidelines. The test data summary sheets from the individual crash test reports are enclosed for reference.

We concur that MASH test 3-36 may be waived because the SOFT-STOP will not be connected to any stiffer device than W-beam guardrail, and test 3-35 showed that the performance of the system when impacted at an angle by the 2270P was satisfactory. We concur that the substitution of the 1100C vehicle to evaluate the reverse direction impact was appropriate. We concur that test 3-38 is not necessary because the SOFT-STOP is not a staged device and that your calculations predict crashworthy performance with the 1500A vehicle.

Findings
Therefore, the system described and detailed in the enclosed letter is eligible for reimbursement and should be installed under the range of conditions tested, when such use is acceptable to a highway agency.

Please note the following standard provisions that apply to FHWA eligibility letters

• This finding of eligibility is limited to the crashworthiness characteristics of the systems and does not cover their structural features, nor conformity with the Manual on Uniform Traffic Control Devices.
• changes that may adversely influence the crashworthiness of the system will require a new letter.
• Should the FHWA discover that the qualification testing was flawed, that in-service performance reveals unacceptable safety problems, or that the system being marketed is significantly different from the version that was crash tested, we reserve the right to modify or revoke this letter.
• You will be expected to supply potential users with sufficient information on design and installation requirements to ensure proper performance.
• You will be expected to certify to potential users that the hardware furnished has essentially the same chemistry, mechanical properties, and geometry as that submitted for review, and that it will meet the crashworthiness requirements of the FHWA and the MASH.
• To prevent misunderstanding by others, this letter of eligibility is designated as number CC-115 and shall not be reproduced except in full. This letter and the test documentation upon which it is based are public information. All such letters and documentation may be reviewed at our office upon request.
• The Trinity SOFT-STOP terminal is a patented product and considered proprietary. If proprietary systems are specified by a highway agency for use on Federal-aid projects, (a) they must be supplied through competitive bidding with equally suitable unpatented items; (b) the highway agency must certify that they are essential for synchronization with the existing highway facilities or that no equally suitable alternative exists; or (c) they must be used for research or for a distinctive type of construction on relatively short sections of road for experimental purposes.
• Our regulations concerning proprietary products are contained in Title 23, Code of Federal Regulations, Section 635.411.
• This letter shall not be construed as authorization or consent by the FHWA to use, manufacture, or sell any patented system for which the applicant is not the patent holder. The finding of eligibility is limited to the crashworthiness characteristics of the candidate system, and the FHWA is neither prepared nor required to become involved in issues concerning patent law. Patent issues, if any, are to be resolved by the applicant.

Enclosures