U.S. Department 

of Transportation 

Federal Highway 

Administration 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

April 1,2020 

In Reply Refer To: 

HSST-1/CC-159 

Mr. Michael J. Buehler 

Trinity Highway Products, LLC 

3617 Cincinnati Ave. 

Rocklin, California 95765 

Dear Mr. Buehler: 

This letter is in response to your December 12, 2019 request for the Federal Highway 

Administration (FHWA) to review a roadside safety device, hardware, or system for eligibility 

for reimbursement under the Federal-aid highway program. This FHWA letter of eligibility is 

assigned FHWA control number CC-159 and is valid until a subsequent letter is issued by 

FHWA that expressly references this device. 

Decision 

The following device is eligible, with details provided in the form which is attached as an 

integral part of this letter: 

• SS180®M 

Scope of this Letter 

To be found eligible for Federal-aid funding, new roadside safety devices should meet the crash 

test and evaluation criteria contained in the American Association of State Highway and 

Transportation Officials’(AASHTO) Manual for Assessing Safety Hardware (MASH). 

However, the FHWA, the Department of Transportation, and the United States Government do 

not regulate the manufacture of roadside safety devices. Eligibility for reimbursement under the 

Federal-aid highway program does not establish approval, certification or endorsement of the 

device for any particular purpose or use. 

This letter is not a determination by the FHWA, the Department of Transportation, or the United 

States Government that a vehicle crash involving the device will result in any particular 

outcome, nor is it a guarantee of the in-service performance of this device. Proper 

manufacturing, installation, and maintenance are required in order for this device to function as 

tested. 

This finding of eligibility is limited to the crashworthiness of the system and does not cover other 

structural features, nor conformity with the Manual on Uniform Traffic Control Devices. 
 

 

 

 

 

 

2 

Eligibility for Reimbursement 

Based solely on a review of crash test results and certifications submitted by the manufacturer, 

and the crash test laboratory, FHWA agrees that the device described herein meets the crash test 

and evaluation criteria of the AASHTO’s MASH. Therefore, the device is eligible for 

reimbursement under the Federal-aid highway program if installed under the range of tested 

conditions. 

Name of system: SS180®M 

Type of system: Truck-Trailer Mounted Attenuator (TTMA) 

Test Level: MASH Test Level 3 (TL3) 

Testing conducted by: KARCO 

Date of request: December 12, 2019 

FHWA concurs with the recommendation of the accredited crash testing laboratory on the 

attached form. 

Full Description of the Eligible Device 

The device and supporting documentation, including reports of the crash tests or other testing 

done, videos of any crash testing, and/or drawings of the device, are described in the attached 

form. 

Notice 

This eligibility letter is issued for the subject device as tested. Modifications made to the device 

are not covered by this letter. Any modifications to this device should be submitted to the user 

(i.e., state DOT) as per their requirements. 

You are expected to supply potential users with sufficient information on design, installation and 

maintenance requirements to ensure proper performance. 

You are expected to certify to potential users that the hardware furnished has the same chemistry, 

mechanical properties, and geometry as that submitted for review, and that it will meet the test 

and evaluation criteria of AASHTO’s MASH. 

Issuance of this letter does not convey property rights of any sort or any exclusive privilege. This 

letter is based on the premise that information and reports submitted by you are accurate and 

correct. We reserve the right to modify or revoke this letter if: (1) there are any inaccuracies in 

the information submitted in support of your request for this letter, (2) the qualification testing 

was flawed, (3) in-service performance or other information reveals safety problems, (4) the 

system is significantly different from the version that was crash tested, or (5) any other 

information indicates that the letter was issued in error or otherwise does not reflect full and 

complete information about the crashworthiness of the system. 

Standard Provisions 
3 

• To prevent misunderstanding by others, this letter ofeligibility designated as FHWA 

control number CC-159 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 upon request. 

• 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. 

• This FHWA eligibility letter is not an expression of any Agency view, position, or 

determination ofvalidity, scope, or ownership of any intellectual property rights to a 

specific device or design. Further, this letter does not impute any distribution or licensing 

rights to the requester. This FHW A eligibility letter determination is made based solely 

on the crash-testing information submitted by the requester. The FHW A reserves the 

right to review and revoke an earlier eligibility determination after receipt of subsequent 

information related to crash testing. 

Sincerely, 

Michael S. Griffith 

Director, Office of Safety Technologies 

Office of Safety 

Enclosures 
 

 

 

 

 

 

 

 

 

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Request for Federal Aid Reimbursement Eligibility

of Highway Safety Hardware 

Submitter Date of Request: December12,2019 New Resubmission 

Name: BretR.Eckert,P.E. 

Company: Trinity Highway Products,LLC 

Address: 3617Cincinnati Ave.,RocklinCA 95765 

Country: USA 

To: Michael S. Griffith, Director 

FHWA, Office of Safety Technologies 

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

highway program. 

Device&TestingCriterion-Enter from right to left startingwith TestLevel ! -! - ! ! -! -! 

SystemType SubmissionType DeviceName / Variant TestingCriterion Test 

Level 

'CC':Truck-Mounted Attenua ' ' 

Attenuators(TMA) 

PhysicalCrashTesting 

Engineering Analysis SS180®M 

AASHTOMASH TL3 

By submitting this request for review and evaluation by the Federal Highway Administration, I 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 Name: MichaelJ.Buehler,P.E. SameasSubmitter 

CompanyName: Trinity Highway Products,LLC SameasSubmitter 

Address: 3617Cincinnati Ave.,RocklinCA 95765 SameasSubmitter 

Country: USA SameasSubmitter 

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

Eligibility Process for Safety Hardware Devices' document. 

TheSS180®MTruckMounted Attenuator (“SS180®MTMA”)system technology is thecommercial embodiment of 

intellectual property that is protected by patentsowned byTrinity Highway Products,LLC("THP").THPdoesnot 

pay royalties for sales of the SS180®M TMA. The SS180®M TMA system was designed and developed by 

engineers and employees at THP. The patent holders of record for the SS180®M TMA system are Michael J. 

Buehler,P.E.,PatrickA.Leonhardt,P.E.,andSeanThompson;andall areemployed byTHP.TheassociatedUnited 

Statespatent, number 9,399,845(DatedSept.11,2013),isassigned toTrinity Highway Products,LLC. 

ApplusIDIADAKarcoEngineering,LLC(KARCO)conducted thecertification testsof theSS180®MTMASystem. 

KARCOisan internationally accredited third party crash testing laboratory. Full-scale crash testing on the 

SS180®M TMA system was performed in accordance with testing criteria, asset forth by the American 

Association of State Highway and Transportation Officials (AASHTO) in the Manual for Assessing Safety 

Hardware("MASH") (2016).Other than feespaid toKARCOto conduct the testsand then analyzeand report the 

test results,KARCOandTHPdo not sharefinancial interests. 
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PRODUCT DESCRIPTION 

Help 

 

TheSS180®Misa mobilecrashcushionattached to the rear of asupport vehicle.It may be used onshadow or 

advancedwarning vehiclesupstream of moving operationsor asa barrier vehicle forstationary work zones. 

TheSS180®Misdesigned to be used onsupport vehicleswith a minimum weight of 13,500lb.anda maximum 

weight of 25,000lb. 

TheSS180®Mconsistsof a frame,hydraulicsand controlssystem,energy absorbing cartridges,lighting, face 

plate, and optionalarrow board / messageboard.Theframeisastructural tubesteel spaceframe that isbolted 

together in sectionsconsisting of an ImpactFrame,Rear Arms,Mid-Frame,Forward Arms,andSupport frame. 

Theframeispowder coated and hasfactory installed decalsand name-plate.Theframehingesin the middle 

and the backhalf can be rotated approximately180° to shorten the length of thesystem when traveling.The 

framemountsto asupport vehicle in a variety of ways.Typical mountsinclude;SocketHitchReceivers, which 

come in variouslengths to accommodate thespecific geometryof thesupport vehicle,andBolt andWeld-on 

systems. 

The SS180®M is 176.5" long by 82" wide. When the system is fully extended, it is 52" high, including the 

nominal height above the ground of 12" ± 1"at the rear of thesystem.Whenfolded in the travel configuration, 

thesystem is94" longand 77" high. Asystem without arrow board weighsapproximately 2030 lbs. 

The hydraulics and controls consist of asingle 3-1/2” cylinder operated by a controls system that folds the 

system into acondensedstatefor transporting to and from theworkzone.Thehydraulicssystem iscontrolled 

either locally at the support frame or remotely with a cabled controller.Electro-mechanical switchesare 

designed to automatically de-energizethe hydraulics when thesystem isfully folded or unfolded. 

There are two energy absorbing cartridges, the rear cartridge “Cartridge A” and the forward cartridge 

“CartridgeB”.Both cartridges consist of aluminum cellsseparated byaluminumsheet diaphragms.Thesides, 

top and bottom, and end are aluminum sheet. The rear of each cartridge isasteel sheet “strong-back” that 

containsfeaturesforattachment to theMid orSupportFrames.Standard lighting consistsof LEDstop, turn, 

tail, and clearance lights. The lighting may be LEDor incandescent and can be manufactured by different 

lighting supply vendors. Thealuminum faceplate isa light-weight assemblydesigned to cover therear of the 

system and improve driver visibility. It isan 0.040” thick aluminum sheet with fabricated bends to fit the 

ImpactFrame. 

Theenergy absorbing andstructural portions of theSS180®Mconsist of the frame,framearms,andcartridges. 

The other ancillary portions of the system, such as hydraulics, controls, and electrical lighting do not absorb 

appreciable amountsof impact energy thereforechanges to thesecomponentswill not affect the performance 

of theSS180®Mduring an impact event. For instance,variousvendors maysupply hydraulic cylinders, hoses, 

pumps, electronic controls and electrical lighting components that perform the same function as the 

componentsthat were present during testing. Thearrow board was present during testing,however, this item 

is not required for proper performance of the SS180®M. The impact face plate may be any color and striped 

with any reflectiveor non-reflective tape of any color,depending on customer requirements. 

CRASH TESTING 

Bysignaturebelow, theEngineer affiliated with the testing laboratory, agreesin support of thissubmission 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 testsare necessary to determine the device meets 

theMASH criteria. 

Engineer Name: StevenMatsusaka 

EngineerSignature: 

Address: 9270HollyRoad,Adelanto,CA.92301 SameasSubmitter 

Country: USA SameasSubmitter ~ 
RequiredTest 

Number 

Narrative 

Description 

Evaluation 

Results 

3-50(1100C) 

ApplusIDIADAKARCOTestNo.P39045-05. 

TestDateJuly 01,2019. CrashTestReport 

No.TR-P39045-05_Dfor MASHTest3-50 

CrashTest ofTrinity HighwayProducts 

SS180®M. 

TheTMAwasimpacted bya2013KiaRio 4-

door sedan. The test vehicle impacted the 

SS180M at a velocity of 61.60 mph (99.14 

km/h) and an impact angle of 0.1°. The 

SS180Mbrought the vehicle to acontrolled 

stop. The maximum measured dynamic 

deformation of the TMA was 7.8 ft (2.4 m). 

Thesupport vehicle rolled aheada distance 

of 2.8ft.(0.9m)asa result of the impact. 

The test vehicle sustained damage to its 

front end.Theengine waspushedrearward 

toward the firewall, the hood deformed 

rearward and upward, and the front 

bumper fascia detached from the vehicle. 

The occupant compartment was not 

penetrated and the deformation limits were 

not exceeded. The Trinity Highway 

ProductsSS180M met all the requirements 

for MASH2016Test3-50. 

PASS 

3-51(2270P) 

ApplusIDIADAKARCOTestNo.P39046-01. 

TestDateJuly 03,2019. CrashTestReport 

No.TR-P39046-01_Cfor MASHTest3-51 

CrashTest ofTrinity HighwayProducts 

SS180®M. 

TheTMAwasimpacted bya2013RAM1500 

4-door pickup truck. The test vehicle 

impacted theSS180Mat a velocity of 61.75 

mph (99.38 km/h) and an impact angle of 

0.3°. The SS180M brought the vehicle to a 

controlled stop. The maximum measured 

dynamic deflection was12.3ft.(3.7m).The 

impact head,both cartridges,andsidearms 

were damaged. The roll ahead distance of 

thesupport truck was9.2ft (2.8m). Thetest 

vehicle sustained damage to its front end. 

The bumper fascia was deformed, the grill 

and hood were both crushed, and the 

engine compartment was damaged. The 

occupant compartment wasnot penetrated 

and the deformation limits were not 

exceeded. The Trinity Highway Products 

SS180Mmet all the requirements for MASH 

2016Test 3-51. 

PASS 

D 

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A brief description of each crash test and its result: Help 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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RequiredTest 

Number 

Narrative 

Description 

Evaluation 

Results 

3-52(2270P) 

ApplusIDIADAKARCOTestNo.P39047-01. 

TestDateJuly 02,2019. CrashTestReport 

No.TR-P39047-01_Cfor MASHTest3-52 

CrashTest ofTrinity HighwayProducts 

SS180®M. 

TheTMAwasimpacted bya2014RAM1500 

4-door pickup truck. The test vehicle 

impacted theSS180Mat a velocity of 63.24 

mph (101.77 km/h) and an offset of 27.4 in 

(697 mm) left of TMA centerline. The 

SS180Mbrought the vehicle to acontrolled 

stop. The maximum measured dynamic 

deflection of thesystem was12.2ft.(3.7m). 

Thesupport vehicle rolled aheadadistance 

of 9.1ft (2.8m)asaresult of the impact. 

The test vehicle sustained damage to its 

front end.Thebumper fasciaand grill were 

torn off. The bumper beam was pushed 

towards theenginecompartment.Theright 

front wheel was punctured. The occupant 

compartment wasnot penetrated and 

the deformation limits were not exceeded. 

The Trinity Highway ProductsSS180M met 

all therequirements for MASH2016Test 

3-52. 

PASS 

3-53(2270P) 

ApplusIDIADAKARCOTestNo.P39048-01. 

TestDateJuly 05,2019. CrashTestReport 

No.TR-P39048-01_Cfor MASHTest3-53 

CrashTest ofTrinity HighwayProducts 

SS180®M. 

TheTMAwasimpacted bya2014RAM1500 

4-door pickup truck. The test vehicle 

impacted theSS180Mat a velocity of 62.44 

mph (100.49km/h)andan impact angle of 

9.6°. The SS180M absorbed the vehicle's 

energy and deflected its trajectory,causing 

thevehicle tospin about itsyaw axisbefore 

coming to rest 54.5ft.(16.6m) forwardand 

22.9ft.(7.0m) left of its position at its initial 

point of contact with theTMA.Thesupport 

truck rolled ahead21.0ft.(6.4m)asaresult 

of the impact. The test vehicle sustained 

damage to its right front end. The front 

bumper and right front quarter panel were 

pushed rearward into the engine 

compartment and the right front wheel 

pushed toward the wheel well. The 

occupant compartment wasnot penetrated 

and the deformation limits were not 

exceeded. The Trinity Highway Products 

SS180Mmet all the requirements for MASH 

2016Test 3-53. 

PASS 

3-54(1500A) Per MASH,this test is optional. Non-Relevant Test,not conducted 
 

 

 

 

 

 

 

 

 

 

 

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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 reports.): 

Laboratory Name: KARCOEngineering, INC 

LaboratorySignature: 

Address: 9270HollyRoad,Adelanto,CA.92301 SameasSubmitter 

Country: USA SameasSubmitter 

Accreditation Certificate 

Number and Dates of current 

Accreditation period : 

International Accreditation Services (IAS) 

ISO17025AccreditationCertificate #TL-371 

ExpiresJuly1,2022 

 

Submit Form 

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 


G

TT

2019 

SS180M TRUCK MOUNTED ATTENUATOR 

~,,, TRINITY 

HIGHWAY 

SWT## 

SHEET NO. 

1 of 2 

DA TE 

12/4/2019 

THP•FE-051 Rev E, 8131/18 
INTENDED USE 

The SS180®M is a mobile crash cushion attached to the rear of a support vehicle. It may be 

used on shadow or advanced warning vehicles upstream of moving operations or as a barrier 

vehicle for stationary work zones. The SS180®M is designed to be used on support vehicles 

with a minimum weight of 13,500 lb. and a maximum weight of 25,000 lb. 

FEATURES 

The SS180®M consists of a frame, hydraulics and controls system, energy absorbing cartridges, 

lighting, face plate, and optional arrow board/ message board. The frame is a structural tube 

steel space frame that is bolted together in sections consisting of an Impact Frame, Rear Arms, 

Mid-Frame, Forward Arms, and Support frame. The frame hinges in the middle and the back 

half can be rotated approximately 180° to shorten the length of the system when traveling. 

SPECIFICATIONS 

• The SS180®M is 176.511 long. 

• Width is 8211 • 

• When the system is fully extended, it is 52" high, including the nominal height above the 

ground of 12" ± 1" at the rear of the system. 

• When folded in the travel configuration, the system is 9411 long and 77" high. 

• A system without arrow board weighs approximately 2030 lbs. 

ELIGIBILITY 

The SMTTM TMA has been fully tested in conformance to MASH 2016 Test Level 3 and is 

determined eligible for Federal reimbursement by FHWA. 

FHWA Eligibility Letter(s): CC-#### dated ________for MASH 2016 Test Level 3 

REFERENCES 

Manual for Assessing Safety Hardware {MASH}, American Assocication of State Highway and 

Transportation Officials (AASHTO), 2016 

CONTACT INFORMATION 

2525 N01th Sternmons Freeway 

Dallas, TX 75207 

Telephone: (888) 323-6374 

Fax: (800) 770-6755 

http ://www. trinity highway .com