1200 New Jersey Ave., SE 

 Washington, D.C. 20590 

1

In Reply Refer To:

HSST-1/CC-177

Andrew Dameron

Hill & Smith

987 Buckeye Park Road

Columbus, OH 43207

USA

Dear Mr. Dameron:

We received your correspondence of January 6, 2023 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-177. 

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.

January 12, 2024
2

Name of system: SMARTPOD

Type of system: Crash Cushion 

Test Level: Test Level 3

Testing conducted by: Applus IDIADA KARCO Engineering, LLC

Date of request: January 6, 2023

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.

Eligibility letter CC-177 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 

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-177. 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 
3

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,

Robert Ritter 

Director, Office of Safety Technologies

Office of Safety

Enclosures
 Version 10.0 (05/16) 

Page 1 of 8 

Request for Federal Aid Reimbursement Eligibility

of Highway Safety Hardware
	

Submitter

 Date of Request: January 06, 2023 New Resubmission 

Name: Andrew Dameron 

Company: Hill & Smith 

Address: 987 Buckeye Park Road, Columbus, OH 43207 

Country: United States of America

 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 ! - ! - ! 

System Type Submission Type Device Name / Variant Testing Criterion Test 

Level 

'CC': Crash Cushions, 

Attenuators, & Terminals 

Physical Crash Testing 

Engineering Analysis 

SMARTPOD 

AASHTO MASH 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. 

Contact Name: Andrew Dameron Same as Submitter 

Company Name: Hill & Smith 

Individual or Organization responsible for the product: 

Same as Submitter 

Address: 987 Buckeye Park Road, Columbus, OH 43207 Same as Submitter

Country: United States of America 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. 

Hill & Smith is the manufacturer and marketer of device. 

Applus IDIADA KARCO Engineering, LLC (IDIADA KARCO) is an independent research and testing laboratory 

having no affiliation with any other entity. IDIADA KARCO is actively Involved In data acquisition and 

compliance/certification testing for a variety of government agencies and equipment manufacturers. The 

principals and staff of IDIADA KARCO have no past or present financial, contractual or organizational interest in 

any company or entity directly or indirectly related to the products that KARCO tests. If any financial interest 

should arise, other than receiving fees for testing, reporting, etc., with respect to any project, the company will 

provide, In writing, a full and immediate disclosure to the FHWA. 
 Version 10.0 (05/16) 

Page 2 of 8 

PRODUCT DESCRIPTION 

New Hardware or 

Significant Modification 

Modification to 

Existing Hardware 

The SMARTPODTM is a redirective, non-gating crash cushion. The SMARTPOD utilizes a rigid dual track base 

frame, telescoping quad formed panels, and energy absorbing pods (Pods) to absorb kinetic energy and safely 

contain or redirect impacting vehicles. The system is comprised of Pods, a baseframe, backstop, middle 

support assemblies (bulkheads), a front support with delineation panel, bulkhead feet, sliding panels, two end 

sliding panels, and panel keeper bolts. The system has a nominal 33 1/2" height and 37 7/16" width at the front 

and 31 13/16" at the rear. The bulkhead widths decrease in width from front to rear to ensure efficient collapse 

upon impact and ease of refurbishment. The test level 3 system measures approximately 270 1/2" (7 Bays) in 

length. The SMARTPOD has anchorage configurations for Concrete foundations or existing roadways. For 

concrete applications a total of 38 anchors are utilized in specifically marked anchor locations. 

SMARTPOD utilizes the proven quad formed panel shape of the Smart Cushion which enables the application 

and interchangeability of several commonly used Smart Cushion transitions to various roadside hardware and 

barrier systems. 

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: B

Brandon Ubina 

randon Ubina 

Engineer Signature: 

Address: 987 Buckeye Park Road, Columbus, OH 43207 Same as Submitter 

Country: United States of America Same as Submitter

 A brief description of each crash test and its result: 

Digitally signed by Brandon Ubina 

DN: cn=Brandon Ubina, o, ou, email=Brandon.ubina@idiada.com, c=US 

Date: 2023.06.01 15:12:57 -07'00' 
 Version 10.0 (05/16) 

Page 3 of 8 

Required Test 

Number 

Narrative 

Description 

Evaluation 

Results 

3-30 (1100C) 

Applus IDIADA KARCO Test No. P42014-01. 

Test Date February 17, 2022. Crash Test 

Report No. TR-P42014-01-NC for MASH 2016 

Test 3-30 Crash Test of Hill & Smith 

SMARTPOD. 

An 1100C test vehicle approached the test 

article at a nominal speed of 62 mph (100 

km/h). The SMARTPOD was oriented at 0° 

and the vehicle's quarter width was 

positioned to the center of the SMARTPOD. 

The SMARTPOD was impacted at a velocity 

of 61.53 mph (99.02 km/h) and an angle of 

0.1°. Upon impact, the 1100C vehicle 

proceeded downstream activating all of the 

attenuating stages on the SMARTPOD. The 

occupant compartment was not penetrated 

and deformation into the occupant 

compartment did not exceed MASH 2016 

recommended limits. The SMARTPOD crash 

cushion met all the requirements for MASH 

Test 3-30. 

PASS 

3-31 (2270P) 

Applus IDIADA KARCO Test No. P42013-02. 

Test Date February 17, 2022. Crash Test 

Report No. TR-P42013-02-NC for MASH 2016 

Test 3-31 Crash Test of Hill & Smith 

SMARTPOD. 

An 2270P test vehicle approached the test 

article at a nominal speed of 62 mph (100 

km/h). The SMARTPOD was oriented at 0° 

and the vehicle's centerline was positioned 

to the center of the SMARTPOD. The 

SMARTPOD was impacted at a velocity of 

64.06 mph (103.09 km/h) and an angle of 

0.2°. Upon impact, the 2270P vehicle 

proceeded downstream activating all of the 

attenuating stages on the SMARTPOD. The 

occupant compartment was not penetrated 

and deformation into the occupant 

compartment did not exceed MASH 2016 

recommended limits. The SMARTPOD crash 

cushion met all the requirements for MASH 

Test 3-31. 

PASS 
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Page 4 of 8 

Required Test 

Number 

Narrative 

Description 

Evaluation 

Results 

3-32 (1100C) 

Applus IDIADA KARCO Test No. P42022-02. 

Test Date MARCH 16, 2022. Crash Test 

Report No. TR-P42022-02-NC for MASH 2016 

Test 3-32 Crash Test of Hill & Smith 

SMARTPOD. 

An 1100C test vehicle approached the test 

article at a nominal speed of 62 mph (100 

km/h). The SMARTPOD was oriented at 15° 

and the vehicle's centerline was positioned 

to the center of the SMARTPOD. The 

SMARTPOD was impacted at a velocity of 

61.66 mph (99.23 km/h) and an angle of 

15.6°. Upon impact, the 1100C vehicle 

proceeded downstream activating all of the 

attenuating stages on the SMARTPOD. The 

occupant compartment was not penetrated 

and deformation into the occupant 

compartment did not exceed MASH 2016 

recommended limits. The SMARTPOD crash 

cushion met all the requirements for MASH 

Test 3-32. 

PASS 

3-33 (2270P) 

Applus IDIADA KARCO Test No. P42094-01. 

Test Date April 28, 2022. Crash Test Report 

No. TR-P42094-01-NC for MASH 2016 Test 

3-33 Crash Test of Hill & Smith SMARTPOD. 

An 2270P test vehicle approached the test 

article at a nominal speed of 62 mph (100 

km/h). The SMARTPOD was oriented at 15° 

and the vehicle's centerline was positioned 

to the center of the SMARTPOD. The 

SMARTPOD was impacted at a velocity of 

62.01 mph (99.80 km/h) and an angle of 

14.4°. Upon impact, the 2270P vehicle 

proceeded downstream activating all of the 

attenuating stages on the SMARTPOD. The 

occupant compartment was not penetrated 

and deformation into the occupant 

compartment did not exceed MASH 2016 

recommended limits. The SMARTPOD crash 

cushion met all the requirements for MASH 

Test 3-33. 

PASS 
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Page 5 of 8 

Applus IDIADA KARCO Test No. P42098-01. 

Test Date May 04, 2022. Crash Test Report 

No. TR-P42098-01-NC for MASH 2016 Test 

3-34 Crash Test of Hill & Smith SMARTPOD. 

An 1100C test vehicle approached the test 

article at a nominal speed of 62 mph (100 

km/h). The SMARTPOD was oriented at 15° 

and the vehicle was aligned to the CIP of 

the SMARTPOD. The SMARTPOD was 3-34 (1100C) PASS impacted at a velocity of 61.83 mph (99.51 

km/h) and an angle of 15.6°. Upon impact, 

the SMARTPOD redirected the vehicle 

downstream within the MASH 2016 exit box 

criteria. The occupant compartment was 

not penetrated and deformation into the 

occupant compartment did not exceed 

MASH 2016 recommended limits. The 

SMARTPOD crash cushion met all the 

requirements for MASH Test 3-34. 
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Page 6 of 8 

Applus IDIADA KARCO Test No. P42099-03. 

Test Date October 07, 2022. Crash Test 

Report No. TR-P42099-03-NC for MASH 2016 

Test 3-35 Crash Test of Hill & Smith 

SMARTPOD. 

An 2270P test vehicle approached the test 

article at a nominal speed of 62 mph (100 

km/h). The SMARTPOD was oriented at 25° 

and the vehicle was aligned to the CIP of 

the SMARTPOD. The SMARTPOD was 

impacted at a velocity of 60.61 mph (97.55 

km/h) and an angle of 25.1°. Upon impact, 

the SMARTPOD redirected the vehicle 

downstream within the MASH 2016 exit box 

criteria. The occupant compartment was 

not penetrated and deformation into the 

occupant compartment did not exceed 

MASH 2016 recommended limits. The 

SMARTPOD crash cushion met all the 

requirements for MASH Test 3-35. 

3-35 (2270P)	 Test 35 was conducted again with the 

SMARTPOD anchored to an asphalt surface. 

Applus IDIADA KARCO Test No. P42234-01. 

Test Date October 21, 2022. Crash Test 

Report No. TR-P42234-01-NC for MASH 2016 

Test 3-35 Crash Test of Hill & Smith 

SMARTPOD. 

PASS 

An 2270P test vehicle approached the test 

article at a nominal speed of 62.00 mph 

(100.00 km/h). The SMARTPOD was oriented 

at 25.0° and the vehicle was aligned to the 

CIP of the SMARTPOD. The SMARTPOD was 

impacted at a velocity of 62.11 mph (99.96 

km/h) and an angle of 25.2°. Upon impact, 

the SMARTPOD redirected the vehicle 

downstream within the MASH 2016 exit box 

criteria. The occupant compartment was 

not penetrated and deformation into the 

occupant compartment did not exceed 

MASH 2016 recommended limits. The 

SMARTPOD crash cushion met all the 

requirements for MASH Test 3-35. 
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Page 7 of 8 

3-36 (2270P) 

Applus IDIADA KARCO Test No. P42051-03. 

Test Date April 20, 2022. Crash Test Report 

No. TR-P42051-03-NC for MASH 2016 Test 

3-36 Crash Test of Hill & Smith SMARTPOD. 

An 2270P test vehicle approached the test 

article at a nominal speed of 62 mph (100 

km/h). The SMARTPOD was oriented at 25° 

and the vehicle's centerline was aligned 

with the centerline of the backup structure. 

The SMARTPOD was impacted at a velocity 

of 63.24 mph (101.78 km/h) and an angle of 

25.4°. Upon impact, the SMARTPOD 

redirected the vehicle downstream within 

the MASH 2016 exit box criteria. The 

occupant compartment was not penetrated 

and deformation into the occupant 

compartment did not exceed MASH 2016 

recommended limits. The SMARTPOD crash 

cushion met all the requirements for MASH 

Test 3-36. 

PASS 

3-37 (2270P) 

Applus IDIADA KARCO Test No. P42097-03. 

Test Date September 26, 2022. Crash Test 

Report No. TR-P42097-03-NC for MASH 2016 

Test 3-37a Crash Test of Hill & Smith 

SMARTPOD. 

An 2270P test vehicle approached the test 

article at a nominal speed of 62 mph (100 

km/h). The SMARTPOD was oriented at 25° 

and the vehicle was aligned to the CIP of 

the SMARTPOD. The SMARTPOD was 

impacted at a velocity of 61.96 mph (99.72 

km/h) and an angle of 25.1°. Upon impact, 

the SMARTPOD redirected the vehicle 

downstream within the MASH 2016 exit box 

criteria. The occupant compartment was 

not penetrated and deformation into the 

occupant compartment did not exceed 

MASH 2016 recommended limits. The 

SMARTPOD crash cushion met all the 

requirements for MASH Test 3-37. 

PASS 

3-38 (1500A) 

Designed to examine the performance of 

crash cushions and end terminals during 

impacts by mid-size vehicles. This test is 

conducted based off the results of Test 3-31. 

Using a force v. deflection diagram the 

estimated value for Occupant Impact 

Velocity (OIV) and Ridedown Acceleration 

(RA) can be found for Test 38. The estimated 

OIV and RA was -11.78 m/s and -13.21 G. 

Therefore, Test 38 was not conducted. 

Non-Relevant Test, not conducted 

3-40 (1100C) 

Test 3-40 is intended for a staged 

attenuation system and is not applicable for 

this system, therefore it was not performed. 

Non-Relevant Test, not conducted 

3-41 (2270P) 

Test 3-41 is intended for a staged 

attenuation system and is not applicable for 

this system, therefore it was not performed. 

Non-Relevant Test, not conducted 
 

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Page 8 of 8 

3-42 (1100C) 

Test 3-42 is intended for a staged 

attenuation system and is not applicable for 

this system, therefore it was not performed. 

Non-Relevant Test, not conducted 

3-43 (2270P) 

Test 3-43 is intended for a staged 

attenuation system and is not applicable for 

this system, therefore it was not performed. 

Non-Relevant Test, not conducted 

3-44 (2270P) 

Test 3-44 is intended for a staged 

attenuation system and is not applicable for 

this system, therefore it was not performed. 

Non-Relevant Test, not conducted 

3-45 (1500A) 

Test 3-45 is intended for a staged 

attenuation system and is not applicable for 

this system, therefore it was not performed. 

Non-Relevant Test, not conducted 

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 KARCO Engineering, LLC. 

Laboratory Signature: Brandon Ubina Digitally signed by Brandon Ubina 

DN: cn=Brandon Ubina, o, ou, email=Brandon.ubina@idiada.com, c=US 

Date: 2023.06.01 15:42:08 -07'00' 

Address: 9270 Holly Road, Adelanto, CA 92301 Same as Submitter 

Country: United States of America Same as Submitter 

Accreditation Certificate 

Number and Dates of current TL 371: April 27, 2022 - April 27, 2025 

Accreditation period : 

Digitally signed by Andrew Dameron

DN: cn=Andrew Dameron, o=Hill & Smith, Inc., 

ou, email=drew.dameron@hillandsmith.com,

c=US

Date: 2023.09.19 17:08:19 -04'00' 

Andrew Submitter Signature*: Dameron 

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