1200 New Jersey Ave., SE

 Washington, D.C. 20590

1 

In Reply Refer To: 

HSST-1/CC-171 

John Annison 

Valmont Highway International Pty Ltd

57-65 Airds Road

Minto, NSW, 2566

Australia

Dear Mr. Annison: 

We received your correspondence of January 13, 2021 requesting issuance of a reimbursement

eligibility letter under the Federal-aid highway program for the roadside safety system, device, 

design, product, or hardware (collectively “device”) described below. This letter is assigned

Federal Highway Administration (FHWA) control number CC-171. 

ELIGIBILITY LETTERS

The FHWA issues Federal-aid reimbursement eligibility letters for new roadside safety devices

that are crash tested in accordance with the industry standard of the American Association of 

State Highway and Transportation Officials (AASHTO) Manual for Assessing Safety Hardware 

(MASH). 

FHWA, the Department of Transportation, and the United States (government) do not regulate 

roadside safety devices, crash test facilities, or the manufacturing industry. Issuance of

eligibility letters is discretionary and provided only as a service to the states. FHWA may, at its

discretion, decline to issue, revise, or rescind an eligibility letter. Eligibility letters are only 

issued by the FHWA headquarters Office of Safety. 

Eligibility letters are issued only as notice to the states that a device is eligible for reimbursement 

under the Federal-aid highway program. They do not establish approval or certification for any 

other purpose. Issuance of an eligibility letter is not a prerequisite or requirement for state 

transportation agencies seeking to use Federal-aid funds for roadside safety devices. State 

agencies may use a device for which an eligibility letter has not been issued and seek Federal-aid

reimbursement. 

FEDERAL-AID REIMBURSEMENT

The request for issuance of this letter certified the device was crash tested in accordance with the 

industry standard of AASHTO’s MASH. This eligibility letter is based on that certification and

the material offered in support of its issuance. The device described below is eligible for

reimbursement under the Federal-aid highway program. 

August 17, 2022
2 

Name of system: ArmorBuffa

Type of system: Crash Cushion 

Test Level: Test Level 3

Testing conducted by: Holmes Solutions LP 

Date of request: January 13, 2021 

Information about the device, including material such as the eligibility request, crash test reports, 

drawings, or images are included in one or more attachment(s) to this letter. 

In accordance with FHWA's Memo "Federal-aid Reimbursement Eligibility Process for Safety

Hardware Devices" dated November 12, 2015, FHWA will make note of any reported damage to 

a test vehicle's fuel tank, oil pan, or other feature that might serve as a surrogate of the fuel tank. 

AASHTO's 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 or rupture of the fuel tank, oil pan, or other feature that might serve as 

a surrogate of the fuel tank should be reported". The test report included in this submittal states 

there was minor damage noted to the vehicle oil pan in Tests 3-40, 3-42, and 3-43. 

Eligibility letter CC-171 is inapplicable to devices, optional equipment, alternate materials, or 

other features that were not crash tested in accordance with AASHTO’s MASH. 

This letter is issued only for the subject device as crash tested under AASHTO’s MASH. Later

modification(s) of the device are not eligible for Federal-aid reimbursement under this letter.

Notice of later modification(s) should be given to transportation agencies, facility owners, and 

operators (collectively “agencies”).

Agencies should be provided appropriate information about the device’s design, installation, 

maintenance, materials, and mechanical properties.

Issuance of this letter is discretionary, and it may be revised or rescinded at FHWA’s discretion. 

This letter is not a determination of compliance with the Manual on Uniform Traffic Control 

Devices for Streets and Highways (MUTCD) or ownership of any intellectual property rights. 

This eligibility letter is not a determination by the government that a crash involving the subject

device will result in any particular outcome. It is limited to only the device’s eligibility for 

Federal-aid reimbursement. 

INTELLECTUAL PROPERTY

Issuance of this eligibility letter does not convey property rights of any sort nor any exclusive 

privilege. This letter is not authorization or consent by the government for the use, manufacture, 

or sale of any patented or proprietary system, device, design, product, or hardware for which the 

requester is not the patent owner. Eligibility letters are not an expression of any view, position, 

or determination by the government as to the validity, scope, or ownership of any intellectual 

property rights to a specific device. These letters do not grant, impute, suggest, or otherwise 

establish any ownership, distribution, or licensing rights to the requester. The government 
3 

expresses no opinion about the intellectual property rights relating to any device for which this or 

any other eligibility letter is issued. 

PUBLIC DISCLOSURE

To prevent any misunderstanding, and as discussed above, this eligibility letter is assigned 

FHWA control number CC-171. It should only be reproduced in full with its attachment(s). 

This letter and the material offered by the requester supporting its issuance is public information. 

All eligibility letters and supporting material are subject to public disclosure under the Freedom 

of Information Act (FOIA). Eligibility letters are available to the public at 

https://safety.fhwa.dot.gov/roadway_dept/countermeasures/reduce_crash_severity/. 

If you have any questions please contact Aimee Zhang at Aimee.Zhang@dot.gov. 

Sincerely,

Michael S. Griffith

Director, Office of Safety Technologies 

Office of Safety

Enclosures 
Version 10.0 (05/16) 

Page 1 of 5 

Request for Federal Aid Reimbursement Eligibility 

 

of Highway Safety Hardware 

Date of Request: | January 13, 2021  New  Resubmissio

Name: | John Annison 

Company: | Valmont Highway International Pty Ltd 

Address: |57-65 Airds Road, Minto, NSW, 2566 

Country: | Australia 

Michael S. Griffith, Director To: FHWA, Office of Safety Technologies 

 

 

 

 Submitter 

I request the following devices be considered eligible for reimbursement under the Federal-aid 

highway program. 

 

 

Device & Testing Criterion - Enter from right to left starting with Test Level ts) 

System Type Submission Type Device Name / Variant Testing Criterion nn 

 Physical Crash Testing AASHTO MASH Ts . . _ |ArmorBuffaTM  Engineering Analysi  'CC: Crash Cushions ‘ Attenuators, & Terminal

 

By submitting this request for review and evaluation by the Federal Highway Administration, | certify 

that the product(s) was (were) tested in conformity with the AASHTO Manual for Assessing Safety 

Hardware and that the evaluation results meet the appropriate evaluation criteria in the MASH. 

 

 

Individual or Organization responsible for the product: 

 

 

Contact 

Company 

Name: 

Name: — 

John 

|Valmont 

Annison 

Highway International 

 

 

Pty Ltd 

 

Address: 57 -65 Airds Road, Minto,NSW, 2566 

Same as Submitter [x] 

Same as Submitter 

Same as Submitter [x] 

Country: Australia Same as Submitter 

 Enter below all disclosures of financial interests as required by the FHWA ‘Federal-Aid Reimbursement 

 

Eligibility Process for Safety Hardware Devices' document. 

Valmont Highway International Pty Ltd and Holmes Solutions LP share no financial interests between the two 

organisations. This includes no shared financial interest but not limited to: 

1. Compensation including wages, salaries, commissions, professional fees, or fees for business referrals. 

 2. Research funding or other forms of research support. 

3. Patents, copyrights, licenses, and other intellectual property interests. 

4, Business ownership and investment interests. 

Holmes Solutions LP completed all of the documented testing activities under a commercial contract with 

Valmont Highway International Pty Ltd. In accordance with the requirements of ISO 17025, all testing activities 

completed by Holmes Solutions LP were undertaken free from any undue commercial influence. For the 

completion of this testing service, Holmes Solutions LP received payment in the form of professional fees. The 

fees received for the testing activities were not linked to the technical performance of the product nor the 

outcome of the tests. 

Holmes Solutions LP does not have, nor ever had, any financial interest in Valmont Highway International Pty 

Ltd. Holmes Solutions LP does not receive any research funding (or other forms of research support) from 

 

Valmont Highway International Pty Ltd. 
Version 10.0 (05/16) 

Page 2 of 5 

 

PRODUCT DESCRIPTION 

 New Hardware or

Significant Modification  Modification to

Existing Hardware 

The ArmorBuffaTM Temporary Crash Cushion is a non-redirective, gating, crash cushion designed to protect the 

ends of temporary concrete safety barrier from errant vehicles. The ArmorBuffaTM is free standing and does not 

require anchoring to the road surface, and can be installed on concrete road surfaces (as tested). 

The ArmorBuffaTM system utilises a steel Transition connection that is bolted to the end of the concrete 

temporary safety barrier, four water-filled plastic segments with interlocking ends and a Nose Piece to absorb 

kinetic energy and safely contain or control the penetration trajectory of impacting errant vehicles. 

The four plastic segments are always filled with water. Each segment contains 185 gallons (700 litres) of water. 

The plastic segments are interlocked by a galvanised steel twin pin at the joint of each segment, and a wire 

rope lanyard is linked to each pin to minimise debris. The system has a nominal height of 43.7 inches 

(1100mm), 20.7 inches (525mm) width, and an effective length of 366.6 inches (9,313mm) for TL-3 when 

installed on temporary concrete barrier. 

For this series of MASH TL-3 tests the ArmorBuffaTM Temporary Crash Cushion was attached to 39.4 Feet (12m) 

of temporary anchored F shaped concrete barrier. 

ArmorBuffaTM passed the series of tests outlined below (3-40, 3-41, 3-42, 3-43 and 3-44) as defined in the 

Manual for Assessing Safety Hardware (MASH), Second Edition, 2016. 

CRASH TESTING 

By signature below, the Engineer affiliated with the testing laboratory, agrees in support of this submission that 

all of the critical and relevant crash tests for this device listed above were conducted to meet the MASH test 

criteria. The Engineer has determined that no other crash tests are necessary to determine the device meets 

 

the MASH criteria. 

 

Engineer Name: | 

 

Emerson 

 

Ryder 

Same as Submitter |] 

Emerson Digitally signed by Emerson Ryder 

 

Engineer Signature: Ryder Date: 2021.01.15 11:26:56 +13'00' 

 

Address: 7 Canterbury 

 

Street, Hornby Christchurch 

Country: New Zealand 

 

 

Same as Submitter |] 

 

A brief description of each crash test andits result: 

Required Test 

Number 

Narrative 

Description 

Evaluation 

 

Results 

 

3-30 (1100C) Non-Relevant Test, not conducted 

 

3-31 (2270P) Non-Relevant Test, not conducted 

 

3-32 (1100C) Non-Relevant Test, not conducted 

 

3-33 ( (2270P) Non-Relevant Test, not conducted 

 

3-34 (1100C) Non-Relevant Test, not conducted 

 

Non-Relevant Test, not conducted 

3-36 (2270P) Non-Relevant Test, not conducted 

 

3-37 ( (2270P) Non-Relevant Test, not conducted 

( 

( 

3-35 (2270P) 

( 

 

3-38 ( (1500A) Non-Relevant Test, not conducted 
Version 10.0 (05/16) 

 

Page 3 of 5 

Required Test Narrative Evaluation 

 

Number Description Results 

The Valmont ArmorBuffa Crash Cushion 

system successfully contained and brought 

to a controlled stop, an 1100C test vehicle 

impacting the test article at 0.0 degrees 

with a % offset and a velocity of 101.5 km/h. 

No debris or detached elements penetrated 

or showed potential to penetrate the 

occupant compartment. No fragments were 

distributed outside of the vehicle trajectory 

and therefore did not present any undue 

hazard to other traffic, pedestrians or work 

zone personnel. 

Occupant risk factors satisfied the test 

criteria and the vehicle exit trajectory 

remained within acceptable limits. Working 

Width was 6.07 m (19.9ft.) 

3-40 (1100C) PASS 

 The Valmont ArmorBuffa Crash Cushion 

system successfully contained and brought 

to a controlled stop, a 2270P test vehicle 

impacting the test article at 0.0 degrees 

with a 0 offset and a velocity of 100.5 km/h. 

No debris or detached elements penetrated 

or showed potential to penetrate the 

occupant compartment. No fragments were 

distributed outside of the vehicle trajectory 

and therefore did not present any undue 

hazard to other traffic, pedestrians or work 

zone personnel. 

Occupant risk factors satisfied the test 

criteria and the vehicle exit trajectory 

remained within acceptable limits. Working 

Width was 1.20 m (3.9ft.) 

3-41 (2270P) PASS 

 The Valmont ArmorBuffa Crash Cushion 

system successfully contained and brought 

to a controlled stop, an 1100C test vehicle 

impacting the test article at 5.1 degrees 

and a velocity of 100.7 km/h. 

No debris or detached elements penetrated 

or showed potential to penetrate the 

occupant compartment. No fragments were 

distributed outside of the vehicle trajectory 

and therefore did not present any undue 

hazard to other traffic, pedestrians or work 

zone personnel. 

Occupant risk factors satisfied the test 

criteria and the vehicle exit trajectory 

remained within acceptable limits. Working 

Width was 4.07 m (13.35ft.) 

3-42 (1100C) PASS 

 
Version 10.0 (05/16)

Page 4 of 5

3-43 (2270P)

The Valmont ArmorBuffa Crash Cushion 

system successfully contained and brought 

to a controlled stop, a 2270P test vehicle 

impacting the test article at 5.4 degrees and 

a velocity of 100.4 km/h.

Width was 3.56 m (11.7ft.)

3-44 (2270P)

The Valmont ArmorBuffa Crash Cushion 

system successfully contained and brought 

to a controlled stop, a 2270P test vehicle 

impacting the test article at 19.9 degrees 

and a velocity of 99.6 km/h.

Width was 3.21 m (10.5ft.)

3-45 (1500A)

Full Scale Crash Testing was done in compliance with MASH by the following accredited crash test 

laboratory (cite the laboratory's accreditation status as noted in the crash test report s.):

Laboratory Name: Holmes Solutions LP

Laboratory Signature: Emerson Ryder Digitally signed by Emerson Ryder

Date: 2022.05 .12 13:02:02 +12'00'

Address: 7 Canterbury Street Hornby Christchurch Same as Submitter 

Country: New Zealand Same as Submitter 

Accreditation Certificate 

Number and Dates of current

Accreditation period:

1022

ISO/IEC 17025:2017 Client Number 7559

Feb 2022 to Feb 2023

Submitter Signature*:

Submit Form
Version 10.0 (05/16) 

Page 5 of 5 

ATTACHMENTS 

Attach to this form: 

1) Additional disclosures of related financial interest as indicated above. 

2) A copy of the full test report, video, and a Test Data Summary Sheet for each test conducted in 

support of this request. 

3) A drawing or drawings of the device(s) that conform to the Task Force-13 Drawing Specifications 

[Hardware Guide Drawing Standards]. For proprietary products, a single isometric line drawing is 

usually acceptable to illustrate the product, with detailed specifications, intended use, and contact 

information provided on the reverse. Additional drawings (not in TF-13 format) showing details that 

are relevant to understanding the dimensions and performance of the device should also be submitted 

to facilitate our review. 

FHWA Official Business Only: 

Eligibility Letter 

 

 

Number Date Key Words