September 10, 2020 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

In Reply Refer To: 

HSST-1/B-348 

Mr. Robby Ramirez 

TrafFix Devices, Inc. 

160 Avenida La Pata 

San Clemente, CA 92673 

USA 

Dear Mr. Ramirez: 

This letter is in response to your January 03, 2020 request for the Federal Highway 

Administration (FHWA) 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 FHWA control number B-348 and is valid until a subsequent letter is issued by FHWA 

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: 

• Lo-Ro Water Cable Barrier 

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: Lo-Ro Water Cable Barrier 

Type of system: Longitudinal Barrier 

Test Level: MASH Test Level 2 (TL2) 

Testing conducted by: Applus IDIADA KARCO Engineering, LLC. 

Date of request: January 3, 2020 

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 crashworthiness of the system. 
3 

Standard Provisions 

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

control number B-348 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 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. 

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 

Submitter 

Date of Request: January 03, 2020 New Resubmission 

Name: Robby Ramirez 

Company: TrafFix Devices, Inc. 

Address: 160 Avenida La PataSan Clemente, CA 92673 

Country: United States 

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 L 

System Type Submission Type Device Name / Variant Testing Criterion Test 

Level 

'B':Rigid/Semi-Rigid Barriers 

(Roadside, Median, Bridge 

Railings) 

PhysicalCrashTesting 

EngineeringAnalysis 

Lo-Ro Water Cable 

Barrier 

AASHTO MASH TL2 

! - ! - !

 

 

 

 

 

evel ! - ! - ! 

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: Robby Ramirez Same asSubmitter 

Company Name: TrafFix Devices, Inc. Same asSubmitter 

Address: 160 Avenida La PataSan Clemente, CA 92673 Same asSubmitter 

Country: United States Same asSubmitter 

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

Eligibility Process for Safety Hardware Devices' document. 

TrafFix Devices Inc. and Applus IDIADA KARCOEngineering LLCshare 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 feesfor businessreferrals 

iii.Research funding or other formsof researchsupport; 

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 

New Hardware or Modification to 

Significant Modification Existing Hardware 

TheLowRotation (Lo-Ro)WaterCableBarrier isa longitudinal barrier designed to contain,redirect andshield 

vehiclesfrom roadsideobstacles.TheLo-RoWaterCableBarrier provides positive protection andseparation 

between the traveling public and personnel in the work zone.TheLo-RoWaterCableBarrier isfreestanding 

and does not require anchoring to the road surface and can be used on concrete, asphalt, gravel, and dirt 

surfaces.Thesurfacesused for testing wereconcreteand dirt.Thesystem consistsof individual water filled 

plastic modules that are connected to adjacent modules creating a continuous barrier wall of unlimited 

maximum length and a minimum length-of-need (LON)of 15connected modules.TheLo-Ro isdesigned and 

tested forTL-2(44mph/70 km/h)applicationsand canalso be used in TL-1(31 mph/50 km/h) applications. 

Theindividual modulesare 75.75in.(1,924mm) long (measured from pin to pin) by22.5in.(572mm) wide by 

36.0in.(914mm) tall.Themodulesare manufactured from white or orangecolored plastic polyethylene that is 

UVstabilized to minimize degradation. Orange and white barrier modules were the as-tested colors, the 

product may be produced in other colors. Molded within the modulesare aseries of three (3) corrosion 

resistant wire rope cables. The cablesare permanently molded into the modules during the manufacturing 

process.Theempty module weightsapproximately 159.0lbs(72.2kg)and the water filled module weights 

approximately1,633.0lbs(740.8kg).Each module isdesigned to utilizean optional drive by float lid for visual 

water levelinspection. 

Themoduleswere designed with a four (4)knuckleend on onesideand a five (5)knuckleend on the opposite 

side.Eachknucklecontainsaseriesof verticallyaligned concentric holesandasteel drop t-pin isinserted into 

theseholes to connect adjacent modules.Whenadjacent modulesare pinned together therearea total of nine 

(9)knucklesaligned with thesteel drop t-pin inserted.Thisprovidesa positiveconnection between adjacent 

modulesand a continuous internal cable barrier within the connected modules. Upon impact the plastic 

modulesruptureand the impacting vehicleengagesand tightens the internal molded cables. 

CRASH TESTING 

Bysignature below, theEngineeraffiliated with the testing laboratory,agreesinsupport of thissubmission 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 testsare necessary to determine the device meets 

theMASH criteria. 

Engineer Name: Steven Matsusaka 

EngineerSignature: Steven Matsusaka DN:cn=Steven Matsusaka,email=steven.matsusaka@idiada.com,c=US Digitally signed by Steven Matsusaka 

Date: 2020.01.24 17:44:38 -08'00' 

Address: 9270 Holly Road, Adelanto, CA 92301 Same asSubmitter 

Country: United States of America Same asSubmitter 

A brief description of each crash test and its result: 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Required Test 

Number 

Narrative 

Description 

Evaluation 

Results 

2-10 (1100C) 

Test report number P39098-01 conducted 

on 03/22/19. Test 2-10 involves an 1100C 

test vehicle impacting the Low Rotation 

Water Cable Barrier at 25° and 44 mph (70 

km/h). The angled impact examines the 

barrier'sability to contain, re-direct or bring 

the vehicle to acontrolledstop.Thevehicle 

should not penetrate the installation while 

controlled lateral deflection of the test 

article isacceptable.The test vehicle,a2013 

Hyundai Accent with a test inertial weight 

of 2,415.1lbs(1,095.5kg),wasset to impact 

the barrier at the CIPas recommended in 

MASH. 

Thevehicle impacted the barrierat aspeed 

and angle of 44.40 mph (71.45 km/h) and 

25.2°, respectively. The barrier contained 

and redirected the vehicle. The vehicle did 

not penetrate, underride, or override the 

installation. The vehicle exited within the 

boundsof theexit box beforecoming to a 

controlled stop. The final resting point of 

the vehicle was 92.4 ft. (28.2 m) 

downstream from itsinitial point of contact 

with the barrier.Thebarrier hada maximum 

dynamic deflection of 6.9ft.(2.1m). 

The Lo-Ro modules remained tethered 

together via thesteel t-pin between module 

knuckles which connects directly to the 

internal molded in steel cables. There were 

no detached elements that showed 

potential to penetrate the vehicle or 

present undue hazards to personnel in a 

work zone. The Occupant Impact Velocities 

(OIV) and Ridedown accelerations were 

within thespecified limitsof MASH.Theroll 

and pitch angles did not exceed 75° and 

there was minimal occupant compartment 

deformation. The Lo-Ro met all the 

requirementsfor MASHTest 2-10. 

PASS 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Version 10.0 (05/16) 

Page 4 of 5 

Required Test 

Number 

Narrative 

Description 

Evaluation 

Results 

2-11 (2270P) 

Test report number P38127-01 conducted 

on 10/02/18. Test 2-11 involves an 2270P 

test vehicle impacting the Low Rotation 

Water Cable Barrier at 25° and 44 mph (70 

km/h). The angled impact examines the 

barrier'sability to contain, re-direct or bring 

the vehicle to acontrolledstop.Thevehicle 

should not penetrate the installation while 

controlled lateral deflection of the test 

article isacceptable.The test vehicle,a2013 

RAM 1500 with a test inertial weight of 

4,948.2 lbs (2,244.5 kg), wasset to impact 

the barrier at the CIPas recommended in 

MASH. 

Thevehicle impacted the barrierat aspeed 

and angle of 44.53 mph (71.67 km/h) and 

25.1°, respectively. The barrier brought the 

vehicle to acontrolled stop.Thevehicledid 

not penetrate, underride, or override the 

installation. The vehicle rotated about its 

yawaxisbeforecoming to acontrolledstop. 

Thefinal resting point of the vehicle was 

28.5 ft. (8.7 m) downstream from its initial 

point of contact with the barrier.Thebarrier 

hada maximum dynamic deflection of 11.8 

ft.(3.6m). 

The Lo-Ro modules remained tethered 

together via thesteel t-pin between module 

knuckles which connects directly to the 

internal molded in steel cables. There were 

no detached elements that showed 

potential to penetrate the vehicle or 

present undue hazards to personnel in a 

work zone. The Occupant Impact Velocities 

(OIV) and Ridedown accelerations were 

within thespecified limitsof MASH.Theroll 

and pitch angles did not exceed 75° and 

there was no occupant compartment 

deformation.TheLo-RoWaterCableBarrier 

met all the requirementsfor MASHTest 

2-11. 

PASS 

2-20 (1100C) Test for transition is not applicable for the 

Lo-Ro Water Cable Barrier. Non-Relevant Test, not conducted 

2-21 (2270P) Test for transition is not applicable for the 

Lo-Ro Water Cable Barrier. 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.):
 

 

 

 

 

 

 

 

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Page 5 of 5 

Laboratory Name: Applus IDIADA KARCOEngineering, LLC 

LaboratorySignature: 

Address: 9270 Holly Road, Adelanto, CA 92301 Same asSubmitter 

Country: United States of America Same asSubmitter 

Accreditation Certificate 

Number and Dates of current 

Accreditation period : 

TL-371: July 2019 - July 2022 

Submitter Signature*:Robert Ramirez Digitally signed by Robert Ramirez 

Date: 2020.01.27 10:45:02 -08'00' 

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 
 

 

General Information Impact Conditions Occupant Risk

Test Agency.......................... Applus IDIADA KARCO Impact Velocity................ 44.40 mph (71.45 km/h) Longitudinal OIV............................... 18.7 ft/s (5.7 m/s)

Test No.................................. P39098-01 Impact Angle............................. 25.2° Lateral OIV.................................... 11.8 ft/s (3.6 m/s)

Test Designation............................ 2-10 Location / Orientation...................... 3.3 ft. Upstream from Pin Longitudinal RA........................... -6.0 g

Test Date............................ 03/22/19 Impact Severity............................. 28.9 kip-ft (39.1 kJ) Lateral RA................................. 3.0 g

THIV.............................................. 24.0 ft/s (7.3 m/s)

Test Article Exit Conditions PHD......................................... 5.4 g

Name / Model....................... Low Rotation Water Cable Barrier Exit Velocity.........................19.55 mph (31.46 km/h) ASI.............................................. 0.68

Type....................................... Free Standing Exit Angle...........................30.8° (after initial redirect)

Installation Length......................158.8 ft. (48.4 m) Final Vehicle Position.................... 92.4 ft. (28.2 m) Downstream Test Article Deflections

Key Elements......................... Standing water filled barrels 5.4 ft. (1.6 m) Left Static............................................. 6.9 ft. (2.1 m)

Road Surface.......................... Concrete Exit Box Criteria Met.......... N/A Dynamic.................................... 6.9 ft. (2.1 m)

Vehicle Snagging................Satisfactory Working Width................................. 8.2 ft (2.5 m)

Test Vehicle Vehicle Pocketing..................Satisfactory Debris Field...........................None

Type / Designation.................... 1100C Vehicle Stability...................... Satisfactory

Year, Make, and Model..............2013 Hyundai Accent Maximum Roll Angle..............1.7 ° Vehicle Damage

Curb Mass............................. 2,469.1 lbs (1,120.0 kg) Maximum Pitch Angle............. 2.2 ° Vehicle Damage Scale................... 11-LFQ-4

Test Inertial Mass................. 2,415.1 lbs (1,095.5 kg) Maximum Yaw Angle............-33.9 ° CDC............................................. 11FLEW4

Gross Static Mass................... 2,588.2 lbs (1,174.0 kg) Maximum Intrusion............................. None

13 TR-P39098-01-A 
 

 

General Information Impact Conditions Occupant Risk

Test Agency...........................IDIADA KARCO Impact Velocity....................44.53 mph (71.67 km/h) Longitudinal OIV..................23.6 ft/s (7.2 m/s) .

Test No..................................... P38127-01 Impact Angle...........................25.1..° Lateral OIV...........................2.6 ft/s (0.8 m/s) .

Test Designation........................ 2-11 . Location / Orientation..................... 2.7 ft. (0.82 m) upstream from pin . Longitudinal RA........................... -4.3 g

Test Date....................... 10/02/18 Impact Severity........................58.6 kip-ft (79.4 kJ) . Lateral RA................................. 2.3 g

THIV............................................. 23.6 ft/s (7.2 m/s) .

Test Article Exit Conditions PHD....................................... 4.5 g ..

Name / Model................. Low Rotation Water Wall Exit Velocity........................N/A. ASI............................................. 0.48 .

Type.................................Longitudinal Barrier Exit Angle...........................N/A

Article Length.................... 6.3 ft. (1.9 m) Final Vehicle Position.................. 28.5 ft. (8.7 m ) Downstream .. Test Article Deflections

Installation Length..................157.8 ft. (48.1 m) 7.1 ft. (2.2 m) Right Static....................................11.5 ft. (3.5 m) .

Road Surface........................Concrete and Soil Vehicle Snagging................Minor Dynamic........................ 11.8 ft. (3.6 m)

Vehicle Pocketing..................Satisfactory Working Width..................13.3 ft. (4.1 m) ..

Test Vehicle Vehicle Stability..................Satisfactory Article Debris Field..................29.5 ft (9.0 m) Downstream ..

Type / Designation..................2270P Maximum Roll Angle............-..24.6° 28.3 ft. (8.6 m) Right

Year, Make, and Model............2013 RAM 1500 . Maximum Pitch Angle............-38. .3° Vehicle Damage

Curb Mass.........................4,772.9 lbs (2,165.0 kg) Maximum Yaw Angle............-47.7° Vehicle Damage Scale.........1-RFQ-4

Test Inertial Mass.................4,948.2 lbs (2,244.5 kg) CDC............................ 01FREW4

Gross Static Mass...............4,948.2 lbs (2,244.5 kg) Maximum Intrusion..............None

13 TR-P38127-01-NC