January 30, 2019 

1200 New Jersey Ave., SE 

Washington , D.C. 20590 

In Reply Refer To: 

HSST-1 /SS-184 

Mr. Micheal Frey 

Frey Manufacturing 

13150 Stewart A venue 

Norwood, MN. 55368 

Dear Mr. Frey: 

This letter is in response to your November 8, 2018 request for the Federal Highway 

Administration (FHW A) 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 FHW A control number SS-184 and is valid until a subsequent letter is issued by FHW A 

that expressly references this device. 

Decision 

The following device is eligible within the length-of-need, with details provided in the form 

which is attached as an integral part of this letter: 

• Pedestrian Signal Pole 

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 FHW A, 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: Pedestrian Signal Pole 

Type of system: Sign Support 

Test Level: MASH Test Level 3 (TL3) 

Testing conducted by: KARCO 

Date ofrequest: November 14, 2018 

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 crash worthiness of the system. 
3 

Standard Provisions 

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

control number SS-184 shall not be reproduced except in full. This letter and the test 

documentation upon which it is ba·sed 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 of validity, 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 FHWA eligibility letter determination is made based solely 

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

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

information related to crash testing. 

• Ifthe subject device is a patented product it may be considered to be proprietary. If 

proprietary systems are specified by a highway agency for use on Federal-aid projects: 

(a) they must be supplied through competitive bidding with equally suitable unpatented 

items; (b) the highway agency must certify that they are essential for synchronization 

with the 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. 

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 

... 

QI 

.E :t:

..c 

::, 

Date of Request: November 08, 2018 (i' New (' Resubmission I 

Name: Robert Ramirez 

Company: Applus IDIADA KARCO Engineering 

Address : 9270 Holly Rd. Adelanto, CA 92301 

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 & Testing Criterion - Enter from right to left starting with Test Level Fl 

System Type Submission Type Device Name/ Variant Testing Criterion Test 

Level 

'SS': Breakaway Sign 

Supports, Mailboxes, & 

other small sion suooorts 

(i' Physical Crash Testing 

(' Engineering Analysis 

Pedestrian Signal Pole 

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: Mike Frey Same as Submitter D 

Company Name: Frey Manufacturing Same as Submitter D 

Address: 13150 Stewart Ave. Norwood, MN 55368 Same as Submitter D 

Country: USA Same as Submitter D 

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

Eligibility Process for Safety Hardware Devices' document. 

Frey Manufacturing and Appl us IDIADA KARCO Engineering LLC share no financial interests between the two 

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

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

iii. Research funding or other forms of research support; 

iv. Patents, copyrights, licenses, and other intellectual property interests; 

vi. Business ownership and investment interests; 
Version 10.0 (05/16) 

Page 2 of 5 

PRODUCT DESCRIPTION 

(e New Hardware or () Modification to 

~ Significant Modification ' Existing Hardware 

The Frey Manufacturing Pedestrian Signal Pole is a support structure composed of circular pipe support and a 

signal pedestal assembly. The as-tested configuration of the Pedestrian Signal Pole was tested with an 

accessible pedestrian signal (APS) push button station and traffic control signal controllers. 

The support was constructed of a 4.5 in. (114 mm) diameter aluminum pipe with a thickness of 0.3 in. (8 mm). 

The pipe had a length of 15.0 ft. (4.6 m). The bottom of the support pipe was threaded into the pedestal 

assembly and secured in place with two (2) set screws. 

The pedestal assembly was composed of a pedestal and access door. The pedestal was 10.0 in. (254 mm) tall 

and had the access door incorporated into one of its sides. The pedestal was anchored to the ground with four 

(4) 0.625 in. (16 mm) diameter by 7.5 in. (191 mm) long threaded studs, four (4) washers, and four (nuts). The 

anchors had an embedment depth of 4.0 in. (102 mm) to 5.0 in. (127 mm). The threaded rods were epoxied 

into a 6.0 in. (152 mm) thick concrete pad for this test. 

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: Robert Ramirez 

Engineer Signature: Ro bert Ramirez Digi tally signed by Robert Ramirez 

ON: cn=Robert Ramirez. o=KARCO Engineering, ou=Project Engineer, 

emafl:a rramirez@karco.com, czUS 

Date: 2018.11.12 14:41'fJ7 -08'00' 

Address: 9270 Holly Rd. Adelanto, CA 92301 Same as Submitter ~ 

Country: USA Same as Submitter ~ 

A brief descri ption of each crash test and its result : 
Version 10.0 (05/16) 

Page 3 of 5 

Required Test 

Number 

Narrative 

Description 

Evaluation 

Results 

3-60 (11 00C) 

Applus IDIADA KARCO test number 

P38168-01.An11 00C test vehicle impacting 

the support at a nominal speed of 1 9 mph 

(30 km/h). This test is designed to evaluate 

the kinetic energy required to activate the 

release mechanism of the support. The test 

vehicle, a 2013 Kia Rio 4-door sedan with a 

test inertial weight of 2,426.1 lbs (1,100.5 

kg) impacted the device at a speed of 18.68 

mph (30.06 km/h). The support was 

activated in a controlled manner and did 

not cause excessive velocity change. The 

device impacted the roof but the 

deformation limits were not exceeded and 

there was no penetration into the occupant 

compartment. The occupant impact 

velocity in the lateral and longitudinal 

direction were 0.3 ft/s (0.1 m/s) and 4.9 ft/s 

(1.5 m/s), respectively. The ridedown 

accelerations in the longitudinal and lateral 

directions were 0.5 g and 1 .0 g, respectively. 

The Frey Manufacturing Pedestrian Signal 

Pole met all the requirements for MASH Test 

3-60. 

PASS 

3-61 (11 00C) 

Applus IDIADA KARCO test number 

P38168-02. An 11 00C test vehicle impacting 

the support at a nominal speed of 62 mph 

(100 km/h). This test is designed to evaluate 

the behavior of the feature during highspeed impacts. The test vehicle, a 2012 Kia 

Rio 4-door sedan with a test inertial weight 

of 2,410.7 lbs (1,093.5 kg) impacted the 

device at a speed of 60.99 mph (98.15 km/ 

h). The support was activated in a controlled 

manner and did not cause excessive 

velocity change . The device rotated over 

the top of the vehicle and did not contact 

the windshield or roof. The occupant impact 

velocity in the lateral and longitudinal 

direction were 0.3 ft/s (1.0 mis) and 1.0 ft/s 

(3.3 mis), respectively. The ridedown 

accelerations in the longitudinal and lateral 

directions were 0.2 g and 0.3 g, respectively. 

The occupant risk values were below the 

preferred values in MASH and there was no 

penetration into the occupant 

compartment. The Frey Manufacturing 

Pedestrian Signal Pole met all the 

requirements for MASH Test 3-61. 

PASS 
Version 10.0 (05/16) 

Page 4 of 5 

Required Test 

Number 

Narrative 

Description 

Evaluation 

Results 

3-62 (2270P) 

Appl us IDIADA KARCO test number 

P38168-03. An 2270P test vehicle impacting 

the support at a nominal speed of 62 mph 

(100 km/ h). This test is designed to evaluate 

the behavior of the feature during highspeed impacts. The test vehicle, a 2012 RAM 

1500 4-door pickup truck with a test inertial 

weight of 5,060.6 lbs (2,295.5 kg) impacted 

the device at a speed of 63.58 mph (101 .75 

km/h). The support was activated in a 

controlled manner and did not cause 

excessive velocity change . There was no 

occupant compartment deformation or 

penetration. There was not sufficient 

velocity change to create occupant impact 

velocities and as a result the ridedown 

accelerations were also zero. The occupant 

risk values were below the preferred values 

in MASH and there was no penetration into 

the occupant compartment. The Frey 

Manufacturing Pedestrian Signal Pole met 

all the requirements for MASH Test 3-62. 

PASS 

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 : Applus IDIADA KARCd Engineering 

Laboratory Signature: RolJert Ramirez Digitally si gned by Robert Ramirez 

DN: cn ... Robert Ramirez, o:: KARCO Engineering, ou=Project Engineer, 

emailzrramirez @karco.com, c:US 

Date: 2018.11.14 09:48:37 -08'00' 

Address : 9270 Hblly Rd. Adelanto, CA 92301 Same as Submitter 0 

Country : USA Same as Submitter 0 

Accreditation Certificate 

Number and Dates of current 

Accreditation period : 

TL-371 Valid up to July 1, 2019 

0,git,I~ 1ig~dbyR~rt Ri1m11u 

Submitter Signature*: Robert Ramirez r:.~~;::,;;;;:;::;~:',';'.

enwll • rr ilTWte~Mco.com.c• US 

0ale: 2018.11 .l .. 09:48.S2-0a'OO' 

Submit Form 

ATTACHMENTS 
Version 10.0 (05/16) 

Page 5 of 5 

Attach to this form: 

I) 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 
MASH Test 3-60 SUMMARY 

0.000 s 0.200 s 0.400 s 0.600 s 1.000 s 

,,,.,,.,., 

ccr m~ 66fti20 •I 

GENERAL INFORMATION 

Test Agency ... .. . 

KARCO Test No....... .. . . 

Test Designation .. . . 

Test Date ................. . . 

TEST ARTICLE 

Name I Model. .. .. ..... . . 

Type ......... .. .. .. ..... .. . . 

Device Height ............ . 

Key Elements .... . .. . . . 

Road Surface ......... ... .. . 

TEST VEHICLE 

Type I Designation ....... . 

Year, Make, and Model. .. . 

Curb Mass ........... ....... . 

Test Inertial Mass ... ... .. ... 

Gross Static Mass ... .. .... . 

KARCO Engineering, LLC. 

P38168-01 

3-60 

06/28/18 

Pedestrian Signal Pole 

Support Structure 

14.8 ft. (4.5 m) 

Support and Pedestal 

Concrete 

1100C 

2013 Kia Rio 

2,538.6 lbs (1,151 .5 kg) 

2,426.1 lbs (1,1 00.5 kg) 

2,590.4 lbs (1 ,175.0 kg) 

Figure 3 Test 3-60 Summary 

Impact Conditions 

Impact Velocity ............... 18.68 mph (30.06 km/h) 

Impact Angle ... ... . ...... ...... 0.0° 

Location/ Orientation .... ..... Offset 17.0 in. (431 mm) 

Kinetic Energy..... ..... .. .. 28.3 kip-ft (38.4 kJ) 

Exit Conditions 

Exit Velocity ...... ..... ..... ... 16.47 mph (26.51 km/h) 

Exit Angle...... . ...... .. ... 0.0° 

Final Vehicle 87.2 ft. (26.6 m ) Downstream 

6.6 ft. (2 m) Right 

Exit Box Criteria Met.. ....... N/A 

Vehicle Snagging .. .. .. ...... .. None 

Vehicle Pocketing .............. None 

Maximum Roll Angle .. ....... . -12.3 ° 

Maximum Pitch Angle .. ... ... 0.8 ° 

Maximum Yaw Angle ...... ... -2.4 ° 

6E 

Occupant Risk 

Longitudinal OIV .... ... ... ..... 0.3 ft/s (0.1 m/s) 

Lateral OIV. ..... .... ........ .... 4.9 ft/ (1 .5 mis) 

Longitudinal RA .... ..... .. ..... 0.5 g 

Lateral RA ...... ... ......... ..... 1.0 g 

THIV. ......................... .... . 4.9 ft/s (1 .5 m/s) 

PHO ... ... .. .... .. ................. 1.1 g 

ASI. . ...... ..... ....... .... ....... 0.16 

Test Article Deflections 

Debris Field (longitudinal) ... 65.3 ft. (19.9 m) 

Debris Field (lateral)........ 7.9 ft. (2.4 m) 

Vehicle Damage 

Vehicle Damage Scale .. .... N/A 

CDC. ..... ... ......... . .... 12TCDW1 

Maximum Intrusion.. ....... .. 2.3 in. (58 mm) 

14 TR-P38168-01-NC 
15 TR-P38168-02-NC 
14 TR-P38168-03-NC 
Top Cap 4" Pipe PEDESTAL BASE 

Grade 

Anchor bolt 

15' PIPE 15'-91⁄2"+- HIGH 

14' PIPE 14'-9 1⁄2"+- HIGH 

13' PIPE 13'-91⁄2"+- HIGH 

or pier 12' PIPE 12'-9 1⁄2"+- HIGH 

11 ' PIPE 11 '-91⁄2"+- HIGH BASE MOUNTING 

10' PIPE 10'-9 1⁄2" +- HIGH 

9' PIPE 9'-91⁄2"+- HIGH 

8' 

6' 

7' 

PIPE 

PIPE 

Pl PE 

8'-9 

6'-9 

7-9 

1⁄2

1⁄2"+

1⁄2"

"+

+

-

-

-

HIGH 

HIGH 

HIGH 

~T

0 

5' Pl PE 5'-9 1⁄2"+- HIGH 

>< 4' PIPE 4'-91⁄2"+- HIGH e 

0.. Access Door 0.. 

<( 

_l_ 

Center of 

Push Button 

~ Approx. 7" --1 

BASE SIDE VIEW 4" Support Pipe 42" (UNLESS 

OTHERWISE 

SPECIFIED) I- 41⁄4"---j 

, r(2) Set Screws - or F--­

/ bolt for cable tether. >( 

e 

0.. 

0.. 

<( 

1 , Ground --i-t--Access Door 

~-+--+--Ground Terminal Terminal

GRADE ~ Approx. 7' --1

CROSSWALK - SIGNAL PEDESTAL ASSEMBLY 

BASE BOTTOM VIEW 

HARDWARE IIED'S OR EXCEEDS STATE SPEClflCATlONS NOT TO SCALE 

IMan!f!!rin~ 

www.FreyMfgCorp.com Made in USA Patent 

9493918 Phone: 952-467-4402 

CROSSWALK- SIGNAL PEDESTAL HEIGHTS 

FOR 

VARIOUS LENGTHS OF 4" PIPES 

CATALOG#: CP6 SERIES 

DATE DWG. NO. REY. 

04-19-18 

8.5.0 1