U.S. Department 

of Transportation 

Federal Highway 

Administration 

June 14, 2023

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

In Reply Refer To: 

HSST-1/B-370 

Adrian Bullock 

Highway Care Ltd 

Denne Court, First Floor South Wing 

Hengist Field, Oad Street 

Borden, Sittingbourne, Kent ME9 8HF 

UK 

Dear Mr. Bullock: 

We received your correspondence of July 12, 2022 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 B-370. 

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. 

1 
 

 

Name of system: HighwayGuard MDS 

Type of system: Longitudinal Barrier 

Test Level: Test Level 3 

Testing conducted by: Holmes Solutions LP 

Date of request: July 12, 2022 

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 B-370 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 B-370. 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 

2 
eligibility letters and supporting material are subject to public disclosure under the Freedom 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, 

Louisa M. Ward 

Acting Director, 

Office of Safety Technologies 

Office of Safety 

Enclosures 

3 
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Page 1 of 5 

12th July 2022 I (i' r 

Adrian Bullock 

Highway Care Ltd 

Denne Court, First Floor South Wing, Hengist Field, Oad Street, Borden, 

Sittingbourne. Kent ME9 8FH. 

UK 

Device & Testing Criterion - Enter from right to left starting with Test Level I ' - ' - ' I 

System Type Submission Type Device Name/ Variant Testing Criterion Test 

Level 

'B': Rigid/Semi-Rigid Barriers 

{Roadside, Median, Bridge 

Railinasl 

Physical Crash Testing AASHTO MASH TL3 

Engineering Analysis HighwayGuard MOS 

Contact Name: Adrian Bullock Same as Submitter [8J 

Company Name: Highway Care Ltd Same as Submitter [8J 

Address: Denne Court, First Floor South Wing, Hengist Field, Oad Street, II Same as Submitter [8J n _ _ _._ t"" :.L.L: -L---- - .,_ .&. AAr-n nr-1 I 

Country: UK Same as Submitter

Holmes Solutions LP completed all of the documented test activities under a commercial contract with Highway 

Care. In accordance with the requirements of of ISO 17025, all testing activities carried out by Holmes Solutions 

LP were undertaken free from any undue commercial influence. For the Completion of this testing service 

Holmes Solutions received payment in the form of professional fees. The fees received for the testing activities 

were not linked to the technical performance of the product nor the outcome of the tests. 

Holmes Solutions LP does not have, nor ever had, any financial interest in Highway Care, and has no ownership 

of any of the products IP. Holmes Solutions does not receive any research funding {or other forms of research 

support from Highway Care. 

 Version 10.0 (05/16)

Submitter

Request for Federal Aid Reimbursement Eligibility

of Highway Safety Hardware

 Date of Request: New Resubmission

Name:

Company:

Address:

Country:

Michael S. Griffith, Director To: FHWA, Office of Safety Technologies 

I request the following devices be considered eligible for reimbursement under the Federal-aid 

highway program.

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:

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

Eligibility Process for Safety Hardware Devices' document.
Page 2 of 5 

New Hardware or 

• Significant Modification 

Modification to 

Existing Hardware 

HighwayGuard is a steel barrier formed from two profiled, thin gauge sheets being welded together along the 

join at the top, and to feet at the base, to form a long hollow section, the over all dimensions of each barrier 

section is 540mm wide at the base, 250mm wide at the top, 800mm high and 6,000mm long. Each longitudinal 

section can be connected to an adjoining section using a unique T-connector which engages with vertical pins 

located at the end of each section. These barrier sections are all joined together and laid out in along the road 

surface to create a longitudinal barrier system {wall). The barrier system can be installed with multiple ground 

anchor configurations. This barrier system incorporates ground anchors at a maximum of 2.0m between 

ground anchors on traffic face of the barrier only in this MDS configuration. 

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. 

Emerson Ryder 

Engineer Signature: Emerson Ryder Digitally signed by Emerson Ryder 

Date: 2023.05.22 10:27:18 + 12'00' 

Same as Submitter D 

New Zealand Same as Submitter D 

 Version 10.0 (05/16)

PRODUCT DESCRIPTION 

CRASH TESTING

Engineer Name:

Address: 7 Canterbury Street Hornby, Christchurch 

Country:

 A brief description of each crash test and its result:
Page 3 of 5 

Required Test 

Number 

Narrative 

Description 

Evaluation 

Results 

The test vehicle impacted the test 

installation approximately 1.1 m upstream 

of the ground anchor (P20) at an angle of 

24.7 degrees and at a velocity of 101.6 km/h. 

• After the initial impact with the barrier, the

front left quarter of the test vehicle begins 

to deform. 

• At approximately 0.05 seconds the test 

vehicle hood is over the top of the barrier 

and deforming the A Pillar area. The top of 

the impacting door briefly opens. 

• At approximately 0.06 seconds the test 

vehicle began to rotate and redirect along 

the face of the barrier. At this time the 

barrier is at maximum deflection of 124 mm. 

• At 0.07 seconds the test vehicle's A Pillar, 

Windscreen and Roof can be seen 

deforming further from the impact. 

• The test vehicle continues to redirect and 

is parallel with the test article at 

approximately 0.18 seconds. 

• The rear of the vehicle impacts the test 

article at 0.22 seconds. 

• At approximately 0.33 seconds after initial 

impact the test vehicle leaves the barrier 

system and came to rest approximately 46 

meters from the CIP. Prior to stopping, the 

test vehicle impacted a perimeter safety 

stop which protects recording equipment. 

This secondary impact caused moderate 

damage to the righthand front quarter of 

the test vehicle which is unrelated to the 

actual test. 

3-10 (1100() PASS 

• The exit trajectory of the vehicle remained 

fully within the designated exit-box of 

MASH, indicating that the vehicle would not 

have presented a hazard to other road 

users. 

The test vehicle reached a maximum vehicle 

roll angle of -14.3 degrees, and a pitch angle 

of -8.4 degrees. The test vehicle had 

approximately 4.0 m of contact with the 

barrier system. 

The maximum working width of the system 

was recorded as 540 mm, with this being 

the width of the footing of the barrier. 

Dynamic deflection was recorded as 124 

mm (4.88 '') measured at the top of the 

barrier. Maximum exterior crush of the 

vehicle from the impact with the test article 

was recorded as 135 mm, this being located 

in the designated crumple-zone of the 

vehicle, namely the left front corner. The 

Footwell on the impact side of the test 

vehicle had 45 mm of crush. The Floor Pan 

had 42 mm of crush located on the impact 

side 

 Version 10.0 (05/16)
Page 4 of 5 

Required Test Narrative Evaluation 

Number Description Results 

A 2270P test vehicle impacted the test 

installation 331 mm upstream of barrier 

joint 3B & 4A and 1.33 m upstream of 

anchor Pl Oat an angle of 25.1 degrees and 

a velocity of 99.9 km/h (62.1 mph). The CIP 

was chosen to maximize the load on the 

joint of the barriers, and also to examine 

potential of test vehicle roll over due to the 

positioning of the ground anchors as per 

Table 2-7 of MASH 16. The test vehicle had 

an approximate contact length of 4.0 

meters (13.12 ft) 

The maximum roll of the vehicle was 

recorded as 24.7 degrees during the impact. 

The maximum working width of the system 

was recorded as 0.52 m (1.71 ft.). The 

maximum dynamic deflection of the system 

was recorded as 0.17 m (0.56 ft) and the 

maximum permanent deflection was 

recorded as 0.08 m (0.26 ft.). 

3-11 (2270P) PASS 

All impact criteria as per MASH Table 5-1 

was met. 

Maximum exterior crush of the vehicle from 

the impact with the test article was 

recorded as 160 mm, this being located in 

the designated crumple-zone of the vehicle, 

namely the left front corner. The Footwell 

on the impact side of the test vehicle had 75 

mm of crush. 

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

3-21 (2270P) Non-Relevant Test, not conducted 

Holmes Solutions LP 

Laboratory Signature: Emerson Ryder Digitally signed by Emerson Ryder 

Date: 2023.05.22 10:28:41 + 12'00' 

7 Canterbury Street Hornby Christchurch Same as Submitter D 

New Zealand Same as Submitter D 

Certificate of Accreditation # 1022 

Client number 7559 

18 April 2023 to 18 April 2024 

Submitter Signature*: 

 Version 10.0 (05/16)

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:

Address:

Country:

Accreditation Certificate 

Number and Dates of current 

Accreditation period :

Submit Form
 

 

 

 

 

 

 

Page 5 of 5 

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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