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LlsDeportn?ent 

tilimqamii 

-;Hghwoy 

Administmfkn 

OcT 12 Is93 

400 Seventh St., SW. 

Washington. D.C. 20590 

Refer to: HNG-14 

John Shewchuk, P.E. 

Manitoba Safe-T-Base 

45 Trottier Bay 

Winnipeg, Manitoba, R3T 3R3 

CAN&DA 

Oear Mr. Shewchuk: 

Thank you for your letter of August 10 requesting Federal Highway 

Administration's (FHWA) acceptance of your company's breakaway couplings for 

use with luminaire supports. Your letter was accompanied by a test report 

from the Southwest Research Institute (SwRI) dated July 1993. Pendulum 

testing was conducted to assess the breakaway,performance of the couplings 

with a steel pole. Requirements for breakaway supports are found in the 1985 

American Association of State Highway and Transportation Officials (AASHTO) 

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Standard Soecifications for Structural Suooorts for Hiahwav Sians. Luminaires 

and Traffic Sionals These specifications have been adopted, with minor 

modifications by the FHWA. 

The tested couplings Model 34M, were made of ASTM A48 Class JO(S) cast iron 

and had axial strengths of 151 kN (34 kips). In 1987, the Federal Outdoor 

Impact Laboratory (FOIL) in McLean, Virginia, tested an earlier model coupling 

with axial strengths of 196 kN (44 kips) which just failed to meet our 

criteria in the low speed test. Your request for acceptance is for the 151 kN 

couplings based upon the SwRI tests and for the 178 kN (40 kips) couplings 

based upon interpolation between the results from testing at the FOIL and 

SwRI. A summary of all the crash testing is presented below: 

Bolt diameter was 25.4 IWI (1 in) in all tests. 

D 

Bolt torque was 544 Nm (400 ft-lb) in all tests. 

*Extrapolation based on procedure in FHWA Notice 5040.20 July 14, 1976. 
2 

The results of the I51 kN coupling tests meet'the change-in-velocity and 

stub-height requirements adopted by the FHWA. The Manitoba Safe-T-Bases 

lklel 34H are therefore acceptable for use on projects on the National Highway 

Systems (NHS) within the range of conditions tested, if proposed by a State. 

The mbxiu mass of pole, plus mast arm, plus luminaire should not exceed 

8 k~ (560 pounds). A drawing of the tested coupler is enclosed. 

You requested that couplings for 28.575-1~1 and 31.75~arm (1 l/a-inch and 

1 l/l-inch) diameter anchor bolts also be found acceptable. As the larger 

bolts would increase the stiffness, and therefore concentrate the breaking 

ferce mre rapidly, we find these larger anchor bolt sizes acceptable. 

(The top bolts, the mounting bolts, are to remain at 25.4-m.) 

We have also reviewed the material you submitted regarding the untested 178 kN 

couplings. You referenced the earlier FOIL tests of the 196 kN couplings 

which passed the high speed test, but failed the low speed test by just a 

small amount. We concur that since the 178 kN couplings have anaxial 

strength of 9 percent less than the I96 kN couplings, it is likely that they 

weuld meet the test criteria. Therefore they are also acceptable, subject to 

the same limitations on the mass of the support structure and attachments as 

given for the 151-kN couplings. 

Our acceptance is limited to the breakaway characteristics of the couplings 

and does not cover their structural features. Presumably, you will supply 

potential users with sufficient information on structural design and 

installation requirements to ensure proper performance. We anticipate that 

the States will require certification from Manitoba Safe-T-Base that the 

hardware furnished has essentially the same chemistry, mechanical properties, 

and geometry as that used in the tests or the alternate materials as described 

above, and that it will meet the FHWA change in velocity requirements. 

Because the Manitoba Safe-T-Base couplings are proprietary, to be used in 

Federal-aid highway projects on the NHS: (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 existing 

highway facilities or that no equally suitable alternate exists; or (c) they 

mst 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, a copy of which is enclosed. 

Another consideration you may wish to take into account involves the Buy 

kerica provisions in the Intermodal Surface Transportation Efficiency Act of 

1991. Section 1048 (a) included iron as a material subject to the Buy America 
3 

requiremes&s. These regutrements, including wajver provisions, are found in 

Title 23 of the Code of Federal Regulations, Section 635.410, a copy of which 

is enclosed. Please note that all manufacturing processes of steel and iron 

materials, including the application of coatings for these materials must 

eccur in the hited States. 

Sincerely yours, 

3 Enclosures 

wrence A. Staron 

Chief, Federal-Aid and Design Division 

Geometric and Roadside Design Acceptance Letter No. LS-33 
STUD 

COUPLER - 

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L0WER WASHER 4 1 

LEVELLING NUT 5 

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SPACER (LENGTH AS d 

REQUIRED ) 

LOCK NUT 8 

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Figure 2. Manufm’s Drawing of Test Article 
Sec. 635.410 Buy America requirements. 

(a) The provisions of this section shall prevail and be given precedence 

ever any reqofrements of this subpart which are contrary to this section. 

However, nothing in this section shall be construed to be contrary to the 

requirements, of Sec. 635.409(a) of this subpart. 

(b) No Federal-aid highway construction project is to be authorized for 

advertiseslent or otherwise authorized to proceed unless at least one of the 

following requirements is met: 

(1) The project either: (1) includes no permanently incorporated steel or 

iron materials, or (ii) if steel or iron materials are to be used, all 

manufacturing processes, including application of a coating for these 

materials must occur in the United States. Coating includes all.processes 

which protects or enhances the value of the material to which the coating is 

applied. 

(2) The State has standard 'contract provisions that require the use of 

domestic materials and products, including steel and iron materials, to the 

same or greater extent as the provisions set forth in this section. 

(3) The State elects to include alternate bid provisions for foreign and 

domestic steel and iron materials which comply with the following 

requirements. Any procedure for obtaining alternate bids based on furnishing 

foreign steel and iron materials which is acceptable to the Division 

Administrator may be used. The contract provisions must (i) require all 

bidders to submit a bid based on furnishing domestic steel and iron materials, 

and (ii) clearly state that the contract will be awarded to the bidder who 

submits the lowest total bid based on furnishing domestic steel and iron 

materials unless such total bid exceeds the lowest total bid based on 

furnishing foreign steel and iron materials by more than 25 percent. 

(4) When steel and iron materials are used in a project, the requirements 

of this section do not prevent a minimal use of foreign steel and iron 

materials, if the cost of such materials used does not exceed one-tenth of one 

percent (0.1 percent) of the total contract cost or $2,500, whichever is 

greater. For purposes of this paragraph, the cost is that shown to be the 

value of the steel and iron products as they are delivered to the project. 

(c) (1) A State may request a waiver of the provisions of this section if; 

(i) The application of those provisions would be inconsistent with the 

public interest; or 

(ii) Steel and iron materials/products are not produced in the United 

States in sufficient and re~asonably available quantities which are of a 

sattsfactory quality. 
2 

(2) A request for waiver, accompanied by supporting information, must be 

submitted in writing to the Regional Federal Highway Administrator (RFHWA) 

through the FHWA Division Administrator. A request must be submitted 

sufficiently in advance of the need for the waiver in order to allow time for 

proper review and action on the request. The RFHWA will have approval 

authority on the request. 

(3) Requests for waivers may be made for specific projects, or for certain 

materials or products in specific geographic areas, or for combinations of 

both, depending on the circumstances. 

(4) The denial of the request by the RFHWA may be appealed by the State to 

the Federal Highway Administrator (Administrator), whose action on the request 

shall be considered administratively final. 

(5) A request for a waiver which involves nationwide public interest or 

availability issues or more than one FHWA region may be submitted by the RFHWA 

to the Administrator for action. 

(6) A request for waiver and an appeal from a denial of a request must 

include facts and justification to support the granting of the waiver. The 

FHWA response to a request or'appeal will be in writing and made available to 

the public upon request. Any request for a nationwide waiver and FHWA's action 

on such a request may be published in the Federal Register for public comment. 

(7) In determining whether the waivers described in paragraph (c)(l) of 

this section will be granted, the FHWA will consider all appropriate factors 

including, but not limited to, cost, administrative burden, and delay that 

would be imposed if the provision were not waived. 

(d) Standard State and Federal-aid contract procedures may be used to 

assure compliance with the requirements of this section.