March 6, 2002

> Refer to: HSA-10/WZ-103A

Mr. Jan Miller

Eastern Metal/USA Sign

1430 Sullivan Street

Elmira, NY 14901-1698

Dear Mr. Miller:

Thank you for your letter of November 19, 2001, amended via facsimile on
December 19, 2001, requesting Federal Highway Administration (FHWA)
acceptance of a number of your company's portable signs and stands as
crashworthy traffic control devices for use in work zones on the
National Highway System (NHS). You requested that we find these devices
acceptable for use on the NHS under the provisions of National
Cooperative Highway Research Program (NCHRP) Report 350 "Recommended
Procedures for the Safety Performance Evaluation of Highway Features"
based on prior crash testing of your devices and interpolation of
results.

**Introduction**

The FHWA guidance on crash testing of work zone traffic control devices
is contained in two memoranda. The first, dated July 25, 1997, titled
"[INFORMATION]{.underline}: Identifying Acceptable Highway Safety
Features," established four categories of work zone devices: Category I
devices were those lightweight devices which could be self-certified by
the vendor, Category II devices were other lightweight devices which
needed individual crash testing, Category III devices were barriers and
other fixed or massive devices also needing crash testing, and Category
IV devices were trailer mounted lighted signs, arrow panels, etc. The
second guidance memorandum was issued on August 28, 1998, and is titled
"[INFORMATION]{.underline}: Crash Tested Work Zone Traffic Control
Devices." This later memorandum lists devices that are acceptable under
Categories I, II, and III.

A brief description of your requests follows:

Request 1. X-602 Hi-level Spring Stand with frangible coupling, for use
with 48 inch diamond,

48 x 60 inch and other sized signs of 0.100 and 0.125 inch thick solid
aluminum substrates, and hollow-core 5/8 inch thick, blow molded HD
Polyethylene substrate with waffle pattern tack-offs and radius corners,
as furnished by the Stabler Companies, mounted at the tested height of

60 inches above grade.

The X-602 stand was accepted in our letter WZ-78A dated June 15, 2001.
It was tested with 48x48 diamond signs of 0.080 aluminum and 5/8 inch
plywood mounted at 60 inches. The tested signs weighed 18 pounds and 30
pounds respectively. This range brackets the weights of the signs you
are presently requesting for use with this stand: 22.6 pounds (0.100
inch thick) and

28.25 pounds (0.0125 inch thick). The high density polyethylene (HDPE)
substrate has not been crash tested, but because its properties are
within the bounds of the plywood and the Endurance substrates, [both of
which have been successfully crash tested on this stand]{.underline}, it
will be acceptable for use.

Because this stand performed in an acceptable manner due in large part
to the frangible coupling we concur that the three requested signs will
also be acceptable for use.

Request 2. Type III Barricade with reinforced plastic posts or
perforated square steel tube post and skid system, using Semi-Rigid
plastic plank rails. To be used with 48x48, 60x48 and smaller signs of
Roll-up, corrugated plastic, hollow-core 5/8 inch thick, blow molded HD
Polyethylene substrate with waffle pattern tack-offs and radius corners
as furnished by the Stabler Companies, Endurance, and 0.080 inch
aluminum panels mounted to lengthened accepted post system 60 inches or
more above grade, above the 3-barricade rails.

Testing was conducted by others on type III barricades. Generic Type III
barricades and acceptable signs to be mounted are covered in our
Acceptance Letter WZ-85 dated

November 15, 2001, a copy of which is enclosed. It permits the use of
lightweight substrate signs attached to the face of the barricade, but
not aluminum or plywood. Your request, however, is for aluminum signs
(and the lightweight signs) mounted above the top rail. We concur in the
use of these substrates and different shapes as long as the height to
the top of the sign is kept at 128 inches (this is the height to the top
of a 48x48 mounted at 60 inches above the pavement.)

Request 3. E-350 Heavy Duty Tripod Stand with 48x48 diamond and smaller
signs of 5/8 inch plywood, 0.100 and 0.125 solid aluminum, and
hollow-core 5/8 inch thick, blow molded

HD Polyethylene substrate with waffle pattern tack-offs and radius
corners, as furnished by the Stabler Companies.

The E-350 was accepted in our letter WZ-78A with various substrates,
mounted at 15 inches above the pavement, the heaviest of which was the
hinged ABS at 23.25 pounds. Based on this test series as well as others
conducted on various portable sign stands with the full range of sign
substrates, we observed that the weight and erratic performance of the
hinged solid ABS material qualifies this item as the "worst case"
substrate. Your request is to use 5/8 inch plywood (30 pounds), 0.125
aluminum (28.25 pounds), and 0.100 aluminum

(22.6 pounds.) We concur with your request for acceptance of additional
substrates based on the successful crash testing of the "worst case"
impact performance hinged 0.250 inch hinged solid ABS plastic in
addition to various rigid and semi-rigid substrates.

Request 4a. X-550 series mid-size stands with hollow-core 5/8 inch
thick, blow molded

HD Polyethylene substrate with waffle pattern tack-offs and radius
corners, as furnished by the Stabler Companies.

The X-550 stands (Model X-552, Model X-553) have been crash tested with
various substrates that bracket the weight and rigidity properties of
the HDPE substrate, therefore it will be acceptable for use under the
same conditions and mounting heights (15 inches) as the other substrates
were tested.

Request 4. The X-550 Series stand has been successfully tested with
0.080 aluminum and found acceptable in FHWA Acceptance Letter WZ-78A.
The X-550b stand includes a frangible aluminum mast is similar in design
and performance to another manufacturer's mid-height breakaway stand
that was successfully tested with 0.080 aluminum and acceptance was
extrapolated to include 15 mm (5/8 inch thick) plywood. Your request is
for acceptance of the X-550b stand with 5/8 inch plywood, 0.100 aluminum
and 0.125 aluminum. Successful tests conducted on the X-600 Series with
plywood and other substrates indicate the significant contribution of
the Frangible Mast System. By integrating this feature into the X-550
Series you believe that the performance of this system will be
comparable to the other manufacturer's

mid-sized dual spring breakaway sign stand currently accepted for use
with various rigid and semi-rigid substrates.

Clearly the safer, lighter weight substrates ought to be used in any
mid-height stand. However, in order to promote a level playing field
among similar product manufacturers, we will consider the use of 5/8
inch plywood on the X-550b stand as acceptable but marginal. Substrates
of 0.100 aluminum are also acceptable. However because of reservations
regarding weight and thickness of the thicker 0.125 inch aluminum, we
are withholding acceptance of the stand with that material.

**Findings**

Your requests 1), 2), 3), 4a), and 4) are acceptable as you asked with
the exception of 0.125 aluminum in Request 3. Request 4 is considered
acceptable but marginal.

The devices described above are acceptable for use on the NHS under the
range of conditions tested, or under the extrapolation conditions
discussed above in your four requests, when proposed by a State.

Please note the following standard provisions that apply to FHWA letters
of acceptance:

-   Our acceptance is limited to the crashworthiness characteristics of
    the devices and does not cover their structural features, nor
    conformity with the Manual on Uniform Traffic Control Devices.

-   Any changes that may adversely influence the crashworthiness of the
    device will require a new acceptance letter.

-   Should the FHWA discover that the qualification testing was flawed,
    that in-service performance reveals unacceptable safety problems, or
    that the device being marketed is significantly different from the
    version that was crash tested, it reserves the right to modify or
    revoke its acceptance.

-   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 acceptance, and that they will
    meet the crashworthiness requirements of FHWA and NCHRP Report 350.

-   To prevent misunderstanding by others, this letter of acceptance,
    designated as number

> WZ-103A shall not be reproduced except in full. This letter, and the
> test documentation upon which this letter is based, is public
> information. All such letters and documentation may be reviewed at our
> office upon request.

-   Eastern Metal/USA Signs stands, barricades, and sign substrates used
    thereon may include patented components and if so are considered
    \"proprietary.\" The use of proprietary work zone traffic control
    devices in Federal-aid projects is generally of a temporary nature.
    They are selected by the contractor for use as needed and removed
    upon completion of the project. Under such conditions they can be
    presumed to meet requirement \"a\" given below for the use of
    proprietary products on Federal-aid projects. On the other hand, if
    proprietary devices are

> specified for use on Federal-aid projects, except exempt, non-NHS
> projects, they: (a) must be supplied through competitive bidding with
> equally suitable unpatented items; (b) the highway agency must certify
> that they are essential for synchronization with 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, a copy of which is
> enclosed.

Sincerely yours,

\\Original signed by\\

> Michael L. Halladay

Acting Program Manager, Safety

Enclosure

FHWA:HSA-10:NArtimovich:tm:x61331:3/04/02

File: WZ103A-JanMillerDecREVFin.wpd

cc: HSA-10 (Reader, HSA-1; Chron File, HSA-10;

N. Artimovich, HSA-10)