Memorandum

Subject: 	 ACTION: Evaluating a State DOT's 

Process to Determine Roadside Safety 

Hardware Crashworthiness on the 

National Highway System (NHS) 

Date: April 9, 2018 

From: MichaelS.Griffith 	

Director, Office of Safety Technologies 	

In Reply Refer To: 

HSA 

To: 	 Division Administrators 


Federal Lands Division Engineers 


Directors of Field Services 


~fl, 

PURPOSE 

The purpose of this memorandum is to provide guidance to the FHWA Division Offices 

to assist in their evaluation that a State DOT has an acceptable process for determining 

the crashworthiness of roadside safety hardware used on the National Highway System 

(NHS). 

BACKGROUND 

The FHWA' s longstanding policy is that all roadside safety hardware installed on the 

NHS be crashworthy. To support this policy, the joint implementation agreement for 

the American Association of State Highway Transportation Officials (AASHTO) 

Manual for Assessing Safety Hardware (MASH) was adopted by AASHTO and 

FHWA. This agreement established dates for implementing AASHTO MASH as the 

criteria for determining crashworthiness of roadside safety hardware. 

The FHW A continues to provide a voluntary service ofreviewing crash test results and 

issues eligibility letters for new roadside safety hardware only. The FHW A no longer 

provides Federal-aid eligibility letters for modifications made to an AASHTO MASHcrash tested device. An eligibility letter is not a requirement for roadside safety 

hardware to be determined eligible for Federal funding. Roadside safety hardware is 

eligible for Federal funding if it has been determined to be crash worthy by the user 

agency (i.e., State DOT). 

An FHWA eligibility letter should not be the sole basis for a State's determination of 

crashworthiness. It is each State' s responsibility to determine crashworthiness and to 

approve new or modified roadside safety hardware meeting the State's specific needs. 

Each State should consider its own operational issues such as installation and 
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maintenance requirements, climate considerations (e.g., use of wood vs. steel posts), 

and in-service performance data in determining what roadside safety hardware to use on 

highway projects. The determination of crashworthiness of roadside safety hardware, 

acceptance for use on highway projects, and installation and maintenance are 

responsibilities handled at the State and local level. 

GUIDANCE 

Each FHWA Division Office should work with its respective State DOT to ensure that 

the State has an acceptable process for determining the crashworthiness of roadside 

safety hardware. Please note that there is no single recognized procedure or standard 

for how State DOTs determine crashworthiness, and existing processes may vary from 

State to State. However, an acceptable process for a State's determination of 

crashworthiness should be fully documented and may include: 

• 	 For new roadside safety hardware: 

o 	 A physical crash test report documenting successful crash testing 

(relative to the AASHTO MASH test criteria) conducted by an ISO 

17025 accredited laboratory. 

• For modifications to existing successfully tested roadside safety hardware: 

o 	 Proprietary devices: an engineering analysis conducted by an ISO 17025 

accredited crash testing laboratory that determines the modification does 

not affect the crashworthiness of the roadside safety hardware based on 

previous crash testing (relative to the AASHTO MASH test criteria). If 

necessary, crash testing may be warranted based on the results of an 

engineering analysis. 

o 	 Generic devices: an engineering analysis as described above can be 

conducted by the State DOT or an ISO 17025 laboratory. Ifnecessary, 

crash testing may be warranted based on the results of an engineering 

analysis. 

The initial determination of the crashworthiness of roadside safety hardware begins 

with laboratory testing and engineering analysis as defined by the AASHTO MASH. 

Once roadside safety hardware is identified as crashworthy and properly installed, 

States are encouraged to collect and assess in-service performance data on how the 

device performs in the vast array of real-world collisions. As selectors of hardware, the 

States are in the best position with complete access to crash data, maintenance 

information, and other critical elements to perform in-service performance evaluations 

and to use that data to make improvements to crash testing criteria and to installation 

and maintenance procedures. States should use all information available to determine 

the continued crashworthiness of roadside safety hardware. 

Chapter 6 in the AASHTO MASH provides guidance on crash testing documentation 

and Chapter 7 provides guidance on in-service performance evaluations. A list of 

Q&As and a guidance document are attached for further clarification. 
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ACTION 

Each FHW A Division Office should ensure that the State DOT has an acceptable 


process in place for determining the crashworthiness of all roadside safety hardware 


installed on the NHS. 


Please report to Will Longstreet, Office of Safety, by June 30, 2018, on the existence of 

an acceptable State DOT process and, if necessary, a timeline for addressing any needed 

improvements. Ifyou have questions or comments, please contact Will at 

will.longstreetra,dot.goy or 202-366-0087. 

Enclosures 

CC: Safety field 
Division Office Guidelines for Reviewing State Processes for Determining Crashworthiness 

of Roadside Safety Hardware 

This guidance is provided to assist the FHW A Division Offices in reviewing a State DOT 

process for determining the crash worthiness of roadside safety hardware used on the National 

Highway System (NHS). 

A State DOT's initial determination of crashworthiness ofroadside safety hardware should begin 

with how the device meets current national testing criteria (i.e. AASHTO Manual on Assessing 

Safety Hardware (MASH)). This initial step often may include full-scale crash testing for new 

devices and/or an engineering analysis (for modifications of crashworthy devices). Below are 

some examples of how devices may be determined and documented as crashworthy that State 

DOTs may implement in their processes. 

1. 	 Research (NCHRP or pooled fund studies) conducted through ISO 17025 accredited 

crash test laboratories (accredited laboratories) showing a device meets AASHTO 

MASH. 

2. 	 Crash test results, videos, and test summary sheets that are completed and reported by 

accredited laboratories and in accordance with AASHTO MASH. 

3. 	 Evaluation of modifications to devices in accordance with AASHTO MASH to determine 

if additional testing is necessary for a device. At the State' s discretion, this may be done 

through a State DOT's analysis for generic products or requiring manufacturers to have 

modifications of proprietary products reviewed by an accredited crash testing lab. 

4. 	 State requirements for manufacturers to have products tested to AASHTO MASH at 

accredited laboratories and to provide a manufacturer's certification that the device meets 

AASHTO MASH criteria supported by concurrence from the accredited crash testing lab. 

5. 	 Consultant review of a device ' s crashworthiness for States that may not have the 


expertise to review roadside safety hardware. 


Once roadside safety hardware is identified as crashworthy and properly installed, States are 

encouraged to collect and assess in-service performance data on how the device performs in the 

vast array of real-world collisions. As selectors of hardware, the States are in the best position 

with complete access to crash data, maintenance information, and other critical elements to 

perform in-service performance evaluations and to use that data to make improvements to crash 

testing criteria and to installation and maintenance procedures. States should use all information 

available to determine the continued crashworthiness of roadside safety hardware. 

Full analysis and review of each device submitted for a determination of crashworthiness should 

also include an operational analysis. This operational analysis may include review and input 

from other State DOT offices including Design, Construction, and Maintenance. 

A State may consider the following when conducting its operational reviews: 

• Is the device appropriate for use in your State? For example, is it appropriate for the State's 

climate; is it compatible with legacy hardware? 

• Will the device be difficult for contractors to install correctly? 

• Will the device be practical to maintain? 

• Will the device require new maintenance protocols and/or inventory stock? 

• Does in-service performance data from other users exist that identify potential issues with 

the device? 
FHW A Division Office Q&As re: a State DOT Determination of Crashworthiness of 

Roadside Safety Hardware 

1. 	 Does roadside safety hardware installed on the NHS need to be crashworthy? 

It is FHW A' s longstanding policy that all roadside safety hardware installed on the NHS be 

crashworthy. This policy is reinforced through design standards incorporated by reference in 

23 CFR part 625, including A Policy on Geometric Design ofHighways and Streets, 2011 

(the AASHTO Greenbook). 

2. 	 What should be considered in determining the crashworthiness of roadside safety hardware? 

The initial determination of the crashworthiness of roadside safety hardware begins with 

laboratory testing and engineering analysis as defined by the AASHTO MASH. This is just 

the first step--proper installation and maintenance of roadside safety hardware also plays a 

crucial role in how hardware will perform. For this reason, States are encouraged to collect 

and assess in-service performance data of roadside safety hardware and take appropriate 

action as needed. As selectors of hardware, the States are in the best position with complete 

access to crash data, maintenance information, and other critical elements to perform inservice performance evaluations and to use that data to make improvements to crash testing 

criteria and to installation and maintenance procedures. States should use all information 

available to determine the continued crashworthiness of roadside safety hardware. 

3. 	 What is the State DOT's role in determining the crash worthiness of roadside safety 

hardware? 

Each State DOT should have a process in place for determining the crashworthiness of new 

and modified roadside safety hardware. This process should include documentation 

supporting the State DOT's determination. 

4. 	 Can a State DOT use an FHW A eligibility letter as the sole basis for determining the 

crashworthiness of a new roadside safety hardware? 

While a State DOT may use an FHW A eligibility letter as one ofthe resources for 

determining crashworthiness, it should not be the sole basis for a State's determination of 

crashworthiness. Each State DOT should document its basis for a determination of 

crashworthiness through review of crash test results and engineering analyses provided by 

accredited crash test labs and manufacturers. It is the State's responsibility to determine the 

appropriateness of new and modified roadside safety hardware for approval and use for its 

needs. Each State should consider its own operational issues such as installation and 

maintenance requirements, climate considerations (e.g., use of wood vs. steel posts), and inservice performance data in determining what roadside safety hardware to place on their 

highway projects. 

5. 	 What is the role of the FHW A Division Office in the process for ensuring crashworthy 

roadside safety hardware is incorporated on the NHS? 
Each FHW A Division Office should ensure that the State DOT has a process in place for 

determining the crashworthiness of all roadside safety hardware installed on the NHS. 

6. 	 Does FHW A require the State DOT to have an FHW A Federal-aid eligibility letter? 

No. Each FHW A Division Office should rely on the State DOT process to establish the 

State's determination of crashworthiness of roadside safety hardware installed on the NHS. 

If a State DOT does not have a process for determining crashworthiness, the Division Office 

should work with the State DOT in developing one. 

7. 	 What is the role of the State DOTs in working with manufacturers regarding modifications? 

An acceptable State process should include a procedure for manufacturers to notify State 

DOTs of modifications to their devices. State DOT processes should address the review of 

modifications. 

8. 	 Must roadside safety hardware be tested to the full matrix of tests recommended in the 

AASHTO MASH to be determined crashworthy? 

No. Running the full matrix of tests recommended in the AAHSTO MASH is only required 

if a State DOT or manufacturer requests an FHW A Federal-aid eligibility letter for a specific 

roadside safety hardware device. The AASHTO MASH allows for user agencies (i.e., State 

DOTs) to determine a critical test matrix for generic devices or to consider a critical test 

matrix developed by a manufacturer. For proprietary devices, State DOTs and manufacturers 

should consider consultation with an accredited crash testing lab in determining critical test 

matrices. 

9. 	 Can modifications be made to roadside safety hardware that has received an FHWA 

eligibility letter? 

Yes. Modifications can be made to roadside safety hardware that has previously received an 

FHWA eligibility letter; however, FHWA no longer considers submissions for Federal-aid 

eligibility letters for modifications made to an AASHTO MASH-crash tested device. The 

State DOT should determine the effect of the modification of roadside safety hardware based 

on the crashworthy criteria established in AASHTO MASH. It is the State DOT's 

responsibility to determine the appropriateness of modified roadside safety hardware for 

approval and use for its needs. 

10. What is considered a significant modification to roadside safety hardware? 

A modification that adversely affects the crash worthy performance of roadside safety 

hardware based on the crash testing criteria in AASHTO MASH is deemed to be significant. 

The determination of significance should be based on engineering analyses. A State DOT 
may choose to have an accredited crash testing lab make this determination. Ifa State DOT 

determines that there has been a significant modification to a previously tested roadside 

safety hardware device, then the relevant manufacturer should retest the device in accordance 

with AASHTO MASH criteria. 

11. Can new and existing research be used to determine crashworthiness of roadside safety 

hardware? 

Yes. A State DOT may consider new and existing research (e.g., NCHRP reports and 

synthesis; individual crash test reports) conducted by an accredited laboratory or qualified 

researchers as part of its process to determine the crashworthiness of roadside safety 

hardware. 

12. Does a State have to make new crashworthiness determinations for existing roadside safety 

hardware currently in place on the NHS? 

No. Existing in-service roadside safety hardware may remain in place until it reaches the end 

of its service life or it becomes damaged beyond repair. Ifthere is interest in continuing with 

the same device for future installations, the owner should determine if the device is 

crashworthy using the latest version of AASHTO MASH criteria.