November 16, 2018 

 1200 New Jersey Ave., SE

Washington, D.C. 20590 

In Reply Refer To: 

HSST-1/B-310 

Mr. Steven J. Conway 

Nucor Steel Marion, Inc. 

912 Cheney A venue 

Marion, Ohio 43302 

Dear Mr. Conway: 

This letter is in response to your August 30, 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 FHW A letter of eligibility is 

assigned FHW A control number B-310 and is valid until a subsequent letter is issued by FHWA 

t.hat 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: 

• 'Nu-Guard-31(5#) Barrier System 

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: Nu-Guard-31(5#) Barrier System 

Type of system: Longitudinal Barrier 

Test Level : MASH Test Level 3 (TL3) 

Testing conducted by: Holmes Solutions 

Date ofrequest: August 30, 2018 

FHW A concurs with the recommendation of the accredited crash testing laboratory within the 

length of need 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. 

Standard Provisions 
3 

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

control number B-310 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 FHW A to use, 

manufacture, or sell any patented system for which the applicant is not the patent holder. 

• This FHW A 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 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. 

• If the 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 63 5 .411. 

Sincerely, 

Michael S. Griffith 

Director, Office of Safety Technologies 

Office of Safety 

Enclosures 
Version 10.0 (05/16) 

Page 1 of 4 

Request for Federal Aid Reimbursement Eligibility 

of Highway Safety Hardware 

... 

CV 

... ... 

·e 

Date of Request: August 30, 2018 r. New G Resubmission I 

Name: Steven J. Conway 

Company: Nucor Steel Marion, Inc. 

Address: 912 Cheney Avenue, Marion, Ohio 43302 

.c 

::, 

V, 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 Fl 

System Type 

'B': Rigid/Semi-Rigid Barriers 

(Roadside, Median, Bridge 

Railinns\ 

Submission Type 

@Physical Crash Testing 

('i Engineering Analysis 

Device Name / Variant 

Nu-Guard-31 (5#) Barrier 

System 

Testing Criterion 

AASHTO MASH 

Test 

Level 

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: Steven J. Conway Same as Submitter [8J 

Company Name: Nucor Steel Marion, Inc. Same as Submitter [8J 

Address: 912 Cheney Avenue, Marion, Ohio 43302 Same as Submitter [8J 

Country: United States of America Same as Submitter [8J 

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

Eligibility Process for Safety Hardware Devices' document. 

There are no shared financial interests in the Nu-Guard-31 (5#) Barrier System between Nucor Steel Marion, Inc. 

and Holmes Solutions, other than the actual crash tests and reports for this submission to FHWA. 
Version 10.0 (05/16) 

Page 2 of 4 

PRODUCT DESCRIPTION 

Ci'i N_ew_ ~ardware ~~ . 

·· S1gnif1cant Mod1f1cat1on 

{l Modification to 

· Existing Hardware 

Longitudinal roadside barriers act to prevent vehicles that depart the road from conflicting with dangerous 

features and hazards on the sides of the roadway. 

The Nu-Guard-31 (5#) Barrier System comprises of all typical Nu_Guard-31 System components. there are no 

modified parts. The W-Beam guardrail height remains the same at 790.0 mm. The height of the post changes 

from the 810.0 mm to 780.0 mm, a difference of 30.0 mm. This means the post bolt sits slightly higher in the 

post slot compared to the configuration installation. 

In summary, the Nu-Guard-31 (5#) Barrier System consists of a W-Beam guardrail, supported on a U section 

posts at 1905 mm centers. The height to the top of the guardrail is specified as a nominal 790.0 mm (31.1 "), and 

for testing purposes installed with an allowable tolerance of +20 mm/ -0 mm. As per the requirements of 

MASH, the test article for Test 3-10 was installed with the rail at the higher tolerance limit and the test article of 

Test 3-11 was installed with the rail at the lower tolerance limit. For the purposes of this tests, all posts were 

driven in AASHTO standard soil. The depth of embedment of the posts was increased to maintain the post 

height below the W-Beam guardrail height. 

The W-Beam rail elements were connected to the posts using M 16 x 90 mm bolts. The lap joints in the rail were 

at 3081 centers, always on a post location. The lap joints were formed with 8 x M 16 splice bolts and nuts. 

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: Emerson Ryder 

Digitally signed by Emerson Ryder 

Date: 2018.08.31 08:35:44 + 12'00' Engineer Signature: Emerson Ryder 

Address: Level 2, 254 Montreal Street, Christchurch 8013 Same as Submitter D 

Country: New Zealand Same as Submitter D 

A brief description ot each crash test and its result: 
Version 10.0 (05/16) 

Page 3 of 4 

Required Test 

Number 

Narrative 

Description 

Evaluation 

Results 

3-10 (1 l00C) 

The CSP Pacific Nu_Guard-31 (5#) 

longitudinal barrier with reduced post 

height, successfully contained and 

redirected an 11 00C test vehicle impacting 

the test article at 24.5 degrees and a 

velocity of 98.0 km/h (60.9 mph). No debris 

or detached elements penetrated or 

showed potential to penetrate the 

occupant compartment. The trajectory of 

the vehicle was such that it did not present 

and undue hazard to other traffic, 

pedestrians or work zone personnel. The 

vehicle remained upright during and after 

impact and vehicle stability was considered 

satisfactory. Occupant risk factors satisfied 

the test criteria and the vehicle exit 

trajectory remained within acceptable 

limits. A link will be sent later to Mr. Griffith 

containing Test Reports, Videos and 

Drawing. 

PASS 

3-1 1 (2270P) 

The CSP Pacific Nu-Guard-31 (5#) 

longitudinal barrier with reduced post 

height, successfully contained and 

redirected a 2270P test vehicle impacting 

the test article at 24.9 degrees and a 

velocity of 97.2 km/h (60.4 mph). No debris 

or detached elements penetrated or 

showed potential to penetrate the 

occupant compartment. The trajectory of 

the vehicle was such that it did not present 

and undue hazard to other traffic, 

pedestrians or work zone personnel. The 

vehicle remained upright during and after 

the impact and vehicle stability was 

considered satisfactory. Occupant risk 

factors satisfied the test criteria and the 

vehicle exit trajectory remained within 

acceptable limits. A link will be sent later to 

Mr. Griffith containing Test Reports, Videos 

and Drawing. 

PASS 

3-20 (11 00C) Non-Relevant Test, not conducted 

3-21 (2270P) 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.) : 
Version 10.0 (05/16) 

Page 4 of 4 

Laboratory Name: Holmes Solutions 

Laboratory Signature: Digitally signed by Emerson Ryder Emerson Ryder Date: 2018.08.31 08:37:46 + 12'00' 

Address: Level 2, Montreal Street, Christchurch 8013 Same as Submitter D 

Country: New Zealand Same as Submitter D 

Accreditation Certificate 

Number and Dates of current 

Accreditation period : 

ISO/IEC 17025:2005;IANZ Certificate Number;l 022 

23 July to Present Day 

Submit Form 

ATTACHMENTS 

Attach to this fonn: 

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 perfonnance of the device should also be submitted 

to facilitate our review. 

FHWA Official Business Only: 

Eligibility Letter 

Number Date Key Words 
@ IANZ 135301.00RP0418 (V1.2) 

z~✓ ACC~~~~!,_O~fOJtY Poge 17 of 33 
 

 

INTENDED USE 

The NU-GUARD-31 TM CSP system is a corrugated metal w-beam barrier for use on national, state 

and local roadways to prevent collisions with hazards as required by safety design standards. The 

system is designed for roadside applications as an alternate to SGR04, and equivalent to other 31" 

[790) mounting height w-beam barriers (such as SGR20), for strong or weak post applications. The 

system may be connected to any crashworthy 31" [790) mounting height guardrail terminal or 

transition system. The system is to be installed on approach slopes no greater than 1 OH : IV, wherever 

a maximum working deflection of 51" [1300) is requ ired for TL-3 applications. 

COMPONENTS 

The posts are Rib-Bak U-Channel sign posts 5 lb/ft [7.4 kg/m] fabricated from hot rolled carbon 

steel bars conforming to the requirements of ASTM A I 075-12 with a minimum yield point of 80,000 

psi [552 Mpa] 

Un it length = 150" [381 OJ 

Designator Component Number 

RWM02a W-beam rail I 

NU-GUARD I 

M 5 lb/ft Line Post 2 

3 1/2" f901 x 1/4" [6] Washer 2 

3 1/2" f901 Guardrail-post bolt and nut 2 

FBB0I Splice bolt and nut 8 

The system meets MASH TL-3 requirements as a longitudinal barrier. 

AGENCY ACCEPTANCE 

N/A 

CONTACT INFORMATION 

Nucor Steel Marion Inc. 

9 12 Cheney A venue 

Marion, Ohio 43 301-180 I 

(800) 333-4011 

(740) 383-6429 Fax 

www.nucorhighwa:t.com 

NU-GUARD-31TM CSP ROADSIDE BARRIER SYSTEM 

SGR33e NUC:CR 

BAR MILL GROUP 

NUCOR STEEL MARION , INC . 

All Nucor Steel Marion Inc. products are produced from I 00% recycled steel. 

SHEET NO. DATE 

2 of2 06/20/2018