US.Department 

of limsportation 

Federal Highway 

Administration 

M·emorandum 

Subject: ACTION: REACT 350 crash cushion 

Elizabeth Alicandri (Q,, ('\ 0 

Associate Administrator for sW'--

Date: SEP 1 4 2016 

From: In Reply Refer To: 

To: Division Administrators 

Directors of Field Services 

Federal Lands Highway Division Engineers 

Purpose 

The purpose of this memorandum is to share information with you regarding a version of 

the REACT 350 crash cushion with a 9 cylinder configuration that was manufactured and 

sold between 1996 and 2007. The infom1ation pertains to a recent voluntary disclosure 

made by Trinity Industries to FHWA regarding a crash test conducted in 2007 that 

exceeded the allowable limit for Occupant Ridedown Acceleration, one of two 

performance factors used to assess occupant risk under National Cooperative Highway 

Research Program (NCHRP) 350 report. 

Background 

On April 12, 1995, FHW A issued a letter of "full acceptance" of a crash cushion called 

the "REACT 350" with various configurations including a 9 cylinder configuration. In late 

1996-1997, the inventor modified the 9 cylinder REACT 350 by changing the three 

rearmost cylinders from 1.4" thickness to 1.8" thickness. Finite Element Analysis (FEA) 

computer modeling and engineering judgement, but not crash testing, was used by the 

inventor to evaluate the crashworthiness of the device with this modification. The 

modified 9 cylinder device was then manufactured and sold to customers by companies 

including Roadway Safety Services Inc. and Energy Absorption Systems (EAS), Inc. from 

1996 to 2007. 

In 2007, EAS had crash tests perfom1ed of the modified 9 cylinder REACT 350 device 

with the three rear most cylinders at 1.8" thickness. The Occupant Ridedown 

Acceleration result of the first crash test was measured at 20.8 G. After these 2007 crash 

test results, EAS stopped manufacturing and selling the modified 9 cylinder REACT 350 

device and reverted back to selling the 9 cylinder REACT 350 device with the three 

reamlost cylinders with 1.4" thickness. In 2010, Trinity acquired EAS. 

Trinity Industries recently voluntarily disclosed to FHW A the results of the 2007 crash 

test. As of the date of this letter, FHWA has been unable to locate any documentation 

HSA-1 
showing that we were aware that EAS had performed this 2007 crash test or of its results. 

NCHRP Report 350 (Report 350) presents criteria used to evaluate the results of crash 

testing of roadside safety hardware. Between 1993 and 2015, FHW A relied on Report 

350 as guidance to determine whether or not a crash test demonstrates that a roadside 

safety hardware device was eligible for Federal-aid funding. Report 350 states the "the 

Occupant Ridedown Accelerations should satisfy a maximum limit of20 G". We have 

interpreted the 20 G value to permit up to 20.49 G due to rounding. 

2 

FHWA evaluated the significance of the modified 9 cylinder REACT 350 exceeding the 

Report 350 maximum recommended limit for ORA. FHW A contacted the National 

Highway Traffic Safety Administration (NHTSA) to gain insight on the risk of serious 

injury when 20.5 G is exceeded. The NHTSA New Car Assessment Program (NCAP) 

rates vehicles relative to their crashworthiness. NCAP gathers vehicle data that can be 

used to show ORA values from crash tests. FHWA reviewed NCAP vehicle data from full 

frontal, rigid barrier crash testing of 67 recent tests on model year 2013 and 20 J 4 vehicles. 

Data gathered from these tests show 88 percent of the vehicles were rated 4 or 5 stars and 

those vehicles had ORA values ranging from 25.6 G up to 58.8 G with an average value of 

35.9 G. 

After evaluating this information, FH WA has concluded that the existence of an ORA 

value slightly above 20.49 G during crash testing does not reflect a dramatically increased 

risk of serious injury in comparison to an ORA value of 20.49 G. FHWA is not aware of 

any additional information relating to the modified REACT 350 to lead FHWA to a 

different conclusion. Notwithstanding that conclusion, FHWA notes that the modified 9 

cylinder REACT 350 device does not meet the NCHRP 350 recommended ORA 

maximum value. 

Action 

Please share this memorandum and the enclosed letter to Trinity with your State DOT and 

any city, county or municipality in your State with responsibility for the operation and 

maintenance of their roadways. FHWA has requested that Trinity notify highway 

agencies of the 2007 test results in a manner reasonably likely to reach all purchasers and 

users of the modified 9 cylinder REACT 350 device. FHWA has also requested that 

Trinity develop a plan to offer modification or replacement of any modified 9 cylinder 

REACT 350 device that an owner or operator identifies. Given the limited ability to 

visually distinguish between the 1.4" and 1.8" thickness cylinders, FHW A has asked 

Trinity to provide guidance and assistance with identifying the modified 9 cylinder 

REACT 350 with 1.8" thickness cylinders. 

If you have questions, please contact Michael Griffith at (202) 366-9469 or 

mike.griffith@dot.gov 

Enclosure 
US. Deportment 

of Transportation 

Federal Highway 

Admlnlst ration 

Scot1 Ewing 

Associate General Counsel 

Trinity Jndustrics, Inc. 

2525 North Stcmmons Frccwny 

Dallas. TX 75207 

Dear Mr. Ewing: 

September 13. 20 16 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

In Reply Refer To: 

HSST-1 

Thank you for your \'oluntary June 9. 2016 response to the federal Highway Administration 

(FH\V A) questions aboul the REA Cl 350. Fl l\V A has reviewed the materials you provided and 

made additional searches for records within our comrol related to U1e REACT 350. This letter 

summarizes the REACT 350 history as understood by Fr-IWA and requests that Trinity Industries 

Inc. (Trinity) make certain additional disclosures and take c..:e rtain actions <lescribed below. 

On April 12, I 995, Fl IW A issued a letter or " l'ull acceptance'· or a crash cushion called the 

"REACT 350" with vnrious configurations including a 9 cylinder conligmation. In late 1996-

1997. the inventor ol' thc device. Dr. Carney. modi lied the 9 cylinder REACT 350 by changing 

the U1ree rearmost cylinders from 1.4" thickness Lo 1.8·· thickness. Dr. Carney used Finite 

Element Analysis (FE/\) computer modeling and cnginccringjudgement. but not crash Lesting. to 

evaluate the crnshworthincss or the device with this modification. The modified 9 cylinder 

device was then manufactured and sold to customers by companies including Road·way Safety 

Services Inc. and gy Absorption Systems (EAS), Inc. Trinity does not have records of who 

purchased this device b11t estimates approximately 900 of these modified 9 cylinder 

configuration devices were purchased between 1996 and 2007. /\s of the date of this leHer, 

Fl I WA has been unable to locale nny documentation showing that any Fl !WA employees 

received notice or any communications related lo this modification to the 9 cylinder REACT 

350. Also. fl I WA has been unable to locate any documentation showing that our agency issued 

an eligibility letter. acccptnnce letter, or any other concurrence for U1is modification. 

ln 2007. EAS had crash tests performed ol' the modilicd 9 cylinder REACT 350 device with the 

three rear mosl cylinders at 1.8'" thickness. The Occupant Ridcdown Acceleration (ORA) result 

of the crash test \VHS measured at 20.8 G. As of the date of this letier. fHW A has been unable to 

locate any documentation showing that Fl 1 WA was aware that EAS had performed this 2007 

crash test or of its results. After these 2007 crash test results. EAS stopped manufacturing and 

selling the modilied 9 cylinder REACT 350 device. The original REACT 350 device with 1.4 .. 

thickness rear cylinders and Lhe Optimized REACT 350 with 1.4 .. rear cylinders both continue to 

have valid eligibility letters from FH\:V A based on results of crash testing. Trinity purchased 

EAS in 20 10. 
2 

As you are aware, NCHRP Report 350 (Report 350) is a research report Fl J\V A uses as guidance 

to evaluate the results of crash testing roadside safcry hardware. Between 1993 and 20 15, Fl IWA 

relied on Report 350 as guidance to determine whether or not a crash test demonstrates that a 

roadside safety hardware device was eligible for Federal-aid funding. Report 350 states the 

·'recommended limits for occupant impact velocity and ORAs [occupanl ridcclown accelerations] 

arc given in Table 5. 1 ... Table 5.1 then stales that the ORAs should salisry a maximum limit of 

20 G. FHWA has interpreted the 20 G value to permit up to 20.49 G clue to rounding. 

FJIWA evaluated the significance of the modified 9 cylinder REACT 350 exceeding lhe Report 

350 maximum recommended limit for ORA. Fl !WA contacted U1e National I lighway Traffic 

Safety Adminislration (NI ITSA) to gnin insight on the risk of serjous injury when 20.5 G is 

exceeded. The NflTSA New Car Asscssmem Program (NCAP) ra tes vehicles relati ve to their 

crashworthiness. NCAP gathers vehi cle data that can be used to show ORA values from crash 

tests. Fl I \VA reviewed NC'AP vehicle data from f'ull frontal, rigid barrier crash testing of 67 

recent tests on model year 2013 and 20 14 vehicles. Data gathered from ihcsc tests show 88 

percent of the vehicles \\'ere rated 4 or 5 stars and those vehicles had ORA values ranging from 

25.6 G up to 58.8 G "ith an average value of J5.9 G. 

Aller evaluating this information, fl IWA has concluded that the ex istence of an ORA value 

slightly above 20.49 G during crash testing docs not renect a dramatically increased risk or 

serious injury in comparison to an OR/\ va lue ol' 20.49 G. FHWA is not mvarc or any additional 

information relating to the modified REACT 350 to lead FHWA ton di fTercnt conclusion. 

Notwithstanding that conclusion, Fl I W J\ notes that the modified 9 cylinder REACT 350 device 

docs not meet the NCI IRP 350 recommended maximum value for ORA. Therefore. FH WA 

requests that Trinity notify highway agencies of the 2007 test results in a manner reasonably 

likely to reach all purchasers and users of the modified 9 cylinder REACT 350 device. FHWA 

also requests that Trinity develop a plan to offer modification or replacement of any modified 9 

cylinder REACT 350 device that an owner or or crator identifies. Given the limited ability to 

visually distinguish between the 1.4·· and 1.8 .. thickness cyljnders, Trinity should also provide 

guidance and assistance with identifying the modified 9 cyl inder REACT 350. 

FHWA intends lo noti ry Lhc FHWA Division Offices who work with each State Department of 

Transportation about the ex istence of these devices on highways. Pl ~e contact me if you have 

any questions or would like to discuss in more detai l. 

Sincerely yours, 

Michael S. GriffiLh 

Director, Office of Safety Technologies