U.S. Department of Transportation
Federal Highway Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
INFORMATION: Federal-aid Reimbursement Eligibility Process For Safety Hardware Devices
|Date: November 12, 2015|
|From||Michael S. Griffith
Director, Office of Safety Technologies
|In Reply Refer To:
Directors of Field Services
Federal Lands Highway Division Engineers
The purpose of this memorandum is to share information on two important changes pertaining to the Federal-aid reimbursement eligibility process for roadside safety hardware and a specific action resulting from one of the changes. The information pertains to: 1) a policy change related to hardware modifications made to devices tested to National Cooperative Highway Research Program Report 350 (NCHRP 350) guidelines, 2) a revision to our Federal-aid reimbursement eligibility process for safety hardware devices, and 3) an action resulting from the revised eligibility process related to devices tested to Manual for Assessing Safety Hardware (MASH) guidelines.
Policy change for hardware modifications for devices tested to NCHRP 350 guidelines
In 2009, the American Association of State Highway and Transportation Officials (AASHTO) published MASH. Since January 1, 2011, FHWA has required that all new roadside safety hardware for which a Federal-aid reimbursement eligibility letter is sought be tested to MASH criteria. For non-significant modifications to hardware originally tested to NCHRP 350 criteria, FHWA has determined Federal-aid eligibility based on analyzing the changes relative to the NCHRP 350 criteria, and has not required new MASH crash testing.
In an effort to encourage installation of MASH crash tested devices, after December 31, 2015, FHWA will not accept requests for Federal-aid eligibility determinations for any modification based on previous crash testing performed using NCHRP 350 criteria. All modifications to an NCHRP 350-tested device will require testing under MASH in order to receive a Federal-aid reimbursement eligibility letter from FHWA.
Going forward, modifications to NCHRP 350-tested devices that have, in the past, been based on engineering analysis, finite element modeling, or through other analysis will no longer receive FHWA eligibility letters. The Federal Register notice announcing this new policy can be found on our website.
Revision to the Federal-aid reimbursement eligibility process
As part of the agency's review to evaluate and improve the eligibility process, FHWA has revised the Federal-aid reimbursement eligibility process for safety hardware devices. The revised process includes many improvements to enhance the quality of the information FHWA receives and increase the transparency of our process. I encourage you to look at the revised process and review the highlights of the changes in FHWA's November 12, 2015 open letter to all in the highway safety hardware and roadside design community.
One change to our process warrants particular attention, as it has led to a specific action. The revised process reads
"An FHWA letter that states a device is eligible for Federal-aid reimbursement may list issues identified by the testing criteria as reportable even if existence of the issue does not represent a failure of the test."
"Although not a specific factor in assessing test results, integrity of the 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 features that might serve as a surrogate of the fuel tank should be reported."
To be fully transparent, the Office of Safety will now document in the Federal-aid reimbursement eligibility letters any information from the related crash test reports of damage to the fuel tank, oil pan, or other features that might serve as a surrogate of the fuel tank.
Action taken for letters related to MASH crash tested devices
Through our recent review of all eligibility letters related to MASH crash tested devices, the following letters have been reissued with new language added since fuel tank (or surrogate) damage was reported in one or more crash tests:
Letter CC-100B: Trinity Slotted Rail Terminal (SRT)
Letter CC-115: Trinity SOFT-STOP Terminal (also called Vertically Loading Terminal)
Please note these devices are still eligible for Federal-aid reimbursement.
These revised letters are attached and can be found at our website http://safety.fhwa.dot.gov/roadway_dept/policy_guide/road_hardware/ where we post all Federal-aid reimbursement eligibility letters.
Division Offices should inform state transportation agencies about these changes to the Federal-aid reimbursement eligibility process for roadside safety hardware and the action resulting from the changes.
If you have any questions or comments, please contact Michael Griffith at (202) 366-9469 or Brian Fouch at (202) 366-0744.