US. Deportment 

of Transportation 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Federal Highway 

Administration December 18, 2015 

In Repl y Refer To: 

HSST/CC-35L 

Mr. Bret Eckert P.E. 

Engineering Applications Manager 

Trinity Highway Products 

36 1 7 Cincinnati A venue 

Rocklin CA 95677 

Dear Mr. Eckert: 

This letter is in response to your August 1. 201-l request for the Federal 11 ighway Administration 

(FHWA) to review a roadside safety device, hardware, or system for eligibili ty for 

reimbursement under the Federal-aid highway program. This FHWA letter of eligibility is 

assigned FHWA control number CC-35L and is valid until a subsequent letter is issued by 

Fl IWA that expressly references this device. 

Decision 

The foll \\ g devices arc eligible, with details provided in the fo1m which is attached as an 

integral part of this letter: 

• QuadGuard System Modifica tion 

Scope of this Letter 

To be found eligible for Pederal-aid funding, modified roadside safety devices should meet the 

crash test and evaluation criteria contained in the National Cooperati ve I lighway Research 

Program (NCHRP) Report 350. However, the Fii WA, the Department of Transportation, and the 

United States Government do not regulate the manufacture of roadside safety devices. Eligibi Iity 

for reimbursement under the Federal-aid highway program docs not establish approval, 

certification or endorsement of the device for any particular purpose or use. 

This letter is not a determination by the FHW A, the Department of Transportation, or the United 

States Government that a vehi cle crash involving the device will result in any particular 

outcome, nor is it a guarantee of the in-service perfo1111 ance of this device. Proper 

manufacturing, installation, and maintenance are required in order for this device to function as 

tested. 
2 

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. 

Eligibility for Reimbursement 

FHWA previously issued an eligibility letter for the roadside safety system described in your 

pending request. Your pending request now identifies a modification to that roadside safety 

system. 

The original roadside safety device information is: 

Name of system: QuadGuard 


Type ofsystem: Crash Cushion 


Date oforiginal request: February 20, 1996 


Date of original FHWA eligibility letter: June 21, 1996 


FHWA Control number: CC-35 


The modification(s) to the QuadGuard covered by this letter are: 

1. Modified the QuadGuard Product Manual to the current Trinity Highway format. In 

addition, the recommended anchor torque value for asphalt was improved from <l 0 ft-lbs to 

10 ft-lbs. 

2. Modified the dimension format on the QuadGuard cartridge box from decimal to fractional 

and changed the molded in company name. Adjusted the tolerances that are consistent with 

typical blow molding process capabilities for items this size. Improved identification of the 

cartridge type on the outside ofthe box from self-adhesive decal to painted on cartridge 

type. 

3. Improved the diaphragm lower reinforcements horizontal fillet weld by increasing total weld 

length on each surface from 17" to 18". 

4. Improved the hinge pivot attachment on the diaphragm hinge plates. 

5. Improved the method of ensuring consistent preloading of the fender panel rear tension 

springs from compressing 1116" to 118", to tightening the nut on mushroom washer bolt until 

it reaches end ofthreads. This method eliminates nut loosening and maintains consistent 

fender panel end gap. The protective coating on the fender panel springs was improved 

from power coated to mechanically galvanized. The spring rate will be unchanged yielding 

superior corrosion protection. 

6. Modified the channel used for Quad Guard transition bracing by adding a I" x 11116" slot for 

galvanizing drainage. 

7. Modified the steel nose on QuadGuard II by adding a small ink "W" letter on the side below 

the attachment holes for identification of wide nose components. 
3 

FHW A concurs with the recommendation of the accredited crash testing laboratory as stated 

within the attached form. 

Full Description of the Eligible Device 

The device and supporting documentation, including reports ofthe crash tests or other testing 

done, videos of any crash testing, and/or drawings of the device, are described in the attached 

form. 

Notice 

Ifa manufacturer makes any modification to any of their roadside safety hardware that has an 

existing eligibility letter from FHWA, the manufacturer must notify FHW A ofsuch modification 

with a request for continued eligibility for reimbursement. The notice of all modifications to a 

device must be accompanied by: 

o 	 Significant modifications - For these modifications, crash test results must be 

submitted with accompanying documentation and videos. 

o 	 Non-signification modifications - For these modifications, a statement from the 

crash test laboratory on the potential effect ofthe modification on the ability of 

the device to meet the relevant crash test criteria. 

FHWA's determination of continued eligibility for the modified hardware will be based 

on whether the modified hardware will continue to meet the relevant crash test criteria. 

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 the NCHRP Report 350. 

Issuance ofthis 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: (I) there are any inaccuracies in 

the information submitted in support ofyour 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. 
4 

Standa rd Provisions 

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

control number CC-35L shall not be reproduced except in full. This letter and the test 

documentation upon which it is based arc public infomrntion. All such letters and 

documentation may be reviewed upon request. 

• 	 This letter shal I not be construed as authorization or consent by the f-HW A to use, 

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

• 	 lf the subject device is a patented product it may be considered to be proprietary. If 

proprietary systems arc speci ficd by a highway agency for use on f-ederal-aid projects: 

(a) they must be suppli ed through competitive bidding with equally suitable unpatentcd 

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) 

Lhey 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 635.41 1. 

Sincerely yours, 

Michael S. Griffith 

Director, Office of Safety Technologies 

Office of Safety 

Enclosures 
Version 9.1 (11/15) 

Page 1 of S 

Request for Federal Aid Reimbursement Eligibility 

ofHighway Safety Hardware 

... 

.~ E 

Date of Request: December 16, 2015 I l'New (i' Resubmission 

Name: Bret R. Eckert, P.E. 

Company: Trinity Highway Products, LLC 

Address: 3617 Cincinnati Ave., Rocklin, CA 95765 

.c 

:;, 

"' Country: USA 

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. 

11-1-11 

System Type Submission Type Device Name I Variant Testing Criterion Test 

Level 

(i' Physical Crash Testing 

(' Engineering Analysis 

QuadGuards System 

NCHRP Report 350 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 NCH RP Report 350 (Report 350) and that 

the evaluation results meet the appropriate evaluation criteria in the Report 350. 

Identification of the individual or organization responsible for the product: 

Contact Name: JimThonn 

Company Name: Trinity Highway Products, LLC 

Address: 70 West Madison Street, Suite 2350, Chicago, IL 60602 

Country: USA 

Same as Submitter D 

Same as Submitter 181 

Same as Submitter D 

Same as Submitter 181 

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

Eligibility Process for Safety Hardware Devices' document. 

The QuadGuards technology is the commercial embodiment of intellectual property that is protected by patents 

that are owned by Trinity Highway Products, LLC (THP). THP does not pay royalties for sales of the QuadGuards 

system. The QuadGuard• system was designed and developed by engineers at Energy Absorption Systems Inc. 

(EAS). The patent holders of record for the QuadGuard0 system are Michael H. Oberth and John V. Machado, 

were employed by EAS. The associated United States Patent Office patent numbers (S,733,062, RE41,988 and 

5,797,592) are assigned to Energy Absorption Systems, Inc./ Trinity Industries, Inc. 

EAS sponsored certain crash tests ofthe QuadGuard11 system; such tests were conducted by E-Tech Testing 

Services, an Independent, wholly-owned subsidiary ofTHP. E-Tech Testing Services Is an International Standards 

Organization ("ISO") 17025 accredited laboratory with American Association for Laboratory Accreditation (A2LA) 

Mechanical Testing certificate 989.01. Full-scale crash testing on the QuadGuard• system was performed In 

accordance with testing criteria, as set forth by the National Cooperative Highway Research Program (•NCHRP") 

in the NCHRP Report 350 (1993). 
Version 9.1 (11/15) 

Page 2 of 5 

PRODUCT DESCRIPTION 

New Hardware or Modification to IN SI lfi t . • on- n 1can r Significant Modification (e' Existing Hardware g 

The QuadGuard5 and QuadGuard5 II systems are redlrectlve, non-gating type crash cushions. The systems 

consists ofenergy absorbing cartridges surrounded by a framework of steel Quad-Beam guardrail that can 

telescope rearward during head-on Impacts. The systems have a center monorail that will resist lateral 

movement during side angle Impacts and a back up structure that will resist rearward movement during headon Impacts. The QuadGuard111 and QuadGuard111 II syste!lls are approved for use per FHWA acceptance letter 

series CC-35 (dated Jun. 21, 1996 thru Nov. 19, 2010. The design changes presented In this submission consist 

ofthe following inconsequential and positive component modifications. 

1) Modified the QuadGuard5 Product Manual to the current Trinity Highway format. In addition, the 

recommended anchor torque value for asphalt was Improved from <10 ft-lbs to 10 ft-lbs. These are 

inconsequential modifications on the QuadGuard5 system. 

2) Modified the dimension format on the QuadGuard" cartridge box from decimal to fractional and changed 

the molded In company name. Adjusted the tolerances that are consistent with typical blow molding process 

capabilities for Items this size. Improved Identification of the cartridge type on the outside of the box from self 

adhesive decal to painted on cartridge type. These are inconsequential modifications on the QuadGuard111 

system. 

3) Improved the diaphragm lower reinforcements horizontal fillet weld by Increasing total weld length on each 

surface from 17" to 18". This Is a positive modification on the QuadGuard111 system. 

4) Improved the hinge pivot attachment on the diaphragm hinge plates. This is a positive modification on the 

QuadGuard" system. 

5) Improved the method ofensuring consistent preloading of the fender panel rear tension springs from 

compressing 1/16" to 1/8", to tightening the nut on mushroom washer bolt until it reaches end of threads. This 

method eliminates nut loosening and maintains consistent fender panel end gap. The protective coating on 

the fender panel springs was improved from power coated to mechanically galvanized. The spring rate will be 

unchanged yielding superior corrosion protection. These are positive modifications on the QuadGuard111 

system. 

6) Modified the channel used for QuadGuard" transition bracing by adding a 1" x 11 /16" slot for galvanizing 

drainage. This is a positive modification on the QuadGuard systems. 

7) Modified the steel nose on QuadGuard" II by adding a small Ink "W" letter on the side below the attachment 

holes for identification of wide nose components. This is an inconsequential modification on the QuadGuard" 

system. 

These component modifications for the QuadGuard" and QuadGuard111 II systems are considered NonSignlflcant. All revisions have been justified through engineering analysis and judgement and have been 

determined to be non-significant and will have no bearing on the as-tested performance ofthe system. 

CRASH TESTING 

A brief description of each crash test and its result: 
Version 9.1 (11/15) 

Page 3 of 5 

Required Test Narrative Evaluation Results Description 

Test No. 01-7620-007, Test Date May 3, 1996, Test Report 

"NCH RP Report 350 Crash Test Results for the QuadGuard 

System, Flnal Report, Project No. 01-7620, May 1996. The nonNumber 

3-30 (820C) PASS significant modlflcations described In the Product Description 

will have no bearing on the as-tested performance of the 

QuadGuard111 system. 

Not Applicable. Test S3-30 Is an optional test and not S3-30 (700C required for QuadGuard111 system eliglblllty. 

Test No. 01-7620-006, Test Date May 1, 1996,Test Report 

"NCHRP Report 350 Crash Test Results for the QuadGuard 

System, Final Report, Project No. 01-7620, May 1996. The non- 3-31 (2000P) PASS slgnlflcant modifications described In the Product Description 

will have no bearing on the as-tested performance of the 

QuadGuard111 system. 

Test No. 01-7620-008, Test Date May 7, 1996, Test Report 

"NCHRP Report 350 Crash Test Results for the QuadGuard 

System, Final Report, Project No. 01-7620, May 1996. The non­ 3-32 (820C) PASS significant modifications described in the Product Description 

will have no bearing on the as-tested performance ofthe 

QuadGuard111 system. 

Not Applicable. Test S3-32 ls an optional test and not S3-32 (7000 required for QuadGuard111 system eligiblllty. 

Test No. 01-7620-005, Test Date Aprll 26, 1996, Test Report 

"NCH RP Report 350 Crash Test Results for the QuadGuard 

System, Final Report, Project No. 01-7620, May 1996. The non­ 3-33 (2000P) PASS significant modifications described in the Product Description 

will have no bearing on the as-tested performance of the 

QuadGuard111 system. 

Not Applicable. Test 3-34 ls for redirectlve, gating devices and 3-34 (820C) not applicable for QuadGuard111system eligibility. 


Not Applicable. Test S3-34 is an optional test and not
 S3-34 (700C) required for QuadGuard" system eligibility. 


Not Applicable. Test 3-35 is for redirectlve, gating devices and
 3-35 (2000P) not applicable for QuadGuard111system eligibility. 

Test No. 01-7620-004, Test Date November 28, 1995, Test 

Report "NCHRP Report 350 Crash Test Results for the 

QuadGuard System, Final Report, Project No. 01-7620, May 3-36 (820C) PASS 1996. The non-significant modifications described in the 

Product Description will have no bearing on the as-tested 

performance of the QuadGuard11 system. 

Not Applicable. Test S3-36 is an optional test and not S3-36 (700C) required for QuadGuard9 system eligibility. 

Test No. 01-7620-002, Test Date November 17, 1995, Test 

Report "NCHRP Report 350 Crash Test Results for the 

QuadGuard System, Final Report, Project No. 01-7620, May 3-37 (2000P) PASS 1996. The non-significant modifications described In the 

Product Description will have no bearing on the as-tested 

performance of the QuadGuard11 system. 

Test No. 01-7620-003, Test Date November 21, 1995, Test 

Report "NCHRP Report 350 Crash Test Results for the 

QuadGuard System, Final Report, Project No. 01-7620, May 3-38 (2000P) PASS 1996. The non-significant modlflcatlons described In the 

Product Description will have no bearing on the as-tested 

performance of the QuadGuard111 system. 
Version 9.1 (11/15) 

Page 4 of 5 

Required Test 

Number 

Narrative 

Description Evaluation Results 

3-39 (2000P) 

3-40 (2000P) 

S3-40 (700C) 

3-41 (2000P) 

3-42 (820C) 

53-42 (7000 

3-43 (2000P) 

3-44 (2000P) 

Test No. 01-7620-001, Test Date November 7, 1995, Test 

Report "NCHRP Report 350 Crash Test Results for the 

QuadGuard System, Final Report, Project No. 01-7620, May 

1996. The non-significant modifications described In the 

Product Description will have no bearing on the as-tested 

performance of the QuadGuard" system. 

Not Applicable. Test 3-40 Is for nonredirective, gating devices 

and not applicable for QuadGuard"system eligibility. 

Not Applicable. Test 53-40 is optional test for nonredirective, 

gating devices and not applicable for QuadGuard"system 

eligibility. 

Not Applicable. Test 3-41 is for nonredirective, gating devices 

and not applicable for QuadGuard"system eligibility. 

Not Applicable. Test 3-42 Is for nonredlrectlve, gating devices 

and not applicable for QuadGuard"system eligibility. 

Not Applicable. Test 53-42 is optional test for nonredirectlve, 

gating devices and not applicable for QuadGuard"system 

eligibility. 

Not Applicable. Test 3-43 Is for nonredirective, gating devices 

and not applicable for QuadGuard"system eliglblllty. 

Not Applicable. Test 3-44 ls for nonredirective, gating devices 

and not applicable for QuadGuard"system eligibility. 

PASS 

Full Scale Crash Testing was done in compliance with NCHRP Report 350 by the following accredited 

crash test Laboratory. By signature below, the Laboratory agrees in support of this submission that all 

critical and relevant crash tests for the device listed above were conducted. (cite the laboratory's 

accreditation status as noted in the crash test reports.): 

Testing Laboratory's signature concurs that these modifications are considered Non-Significant. 

Laboratory Name: E-Tech Testing Services, Inc. 

Laboratory Signature: Paul Kruse Olg<Ul>y •llJned by p..,1 KIUH 

DN:cn•Paul Krus~ oaE·TECH Tntlng Sl'rvkft.04.l .. Pl.ant IS7'. 

•ma.il•paul.truse~n.ftft. C•US 

D.ir. 20U.IZ.17 lll38D8 ·08'00 

Address: 36178 Cincinnati Ave., Rocklin, CA 95765 Same as Submitter D 

Country: USA Same as Submitter ~ 

Accreditation Certificate 

Number and Dates of current A2LA Certificate# 989.01, November 30, 2017 

Accreditation period : 

Olgitolly sJgftOd by

•tt Si t • b k ret.ec ert@trin. -..-..,... S b u m1 er gna ure : t EJ>l,~

ne o..r. 201s.12.111CU11<27 ·0S'OO' 

Submit Form 

AITACHMENTS 

Version 9.1 (11/ 15) 

Page 5 of 5 

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 lo the Task f'orce- 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 fac ilitate our review. 

FHWA Officia l Business Onlv: 

Eligibi lity Letter AASHTO TF13 

Number Date Designator Key Words 
....._ TRINITY 


3617 Cincinnati Ave, Rocklin, CA 95765 

(916) 645-8181 Fax No (916) 645-3495 

October 30, 2015 

Mr. William P. Longstreet 

Highway Engineer, Safety Design Team 

Office of Safety Technologies, Rm E71-107 

Federal Highway Administration 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: QuadGuarcl® Disclosure of Financial Interest, FHWA Review for Eligibility Letter 

Mr. Longstreet, 

On behalf of Trinity Highway Products, LLC ("THP"), I am responding to your 

email requesting details of any financial interest that the crash test laboratory has in the 

QuadGuard® system, manufactured by THP. 

As noted in THP's request for eligibility for reimbursement under the Federal-aid 

highway program for this product, the QuadGuard® system was previously deemed 

eligible by the FHWA, pursuant to HNG-14/CC-35, HNG-14/CC-35A, HNG-14/CC-358, 

HMHS/CC-35C, HSA-1/CC-35D, HSA-10/CC-35E, HSA-10/CC-35F, HSA-10/CC-35G, 

HSSD/CC-35H, HSSD/CC-351, HSSl/CC-35J, HNG-14/CC-42, HSA-10/CC-42A, & 

HSSD/CC-428. 

The QuadGuard® technology is the commercial embodiment of intellectual 

property that is protected by patents that are owned by THP. THP does not pay 

royalties for sales of the QuadGuard® system. The QuadGuard® system was designed 

and developed by engineers at Energi Absorption Systems Inc. (EAS). The patent 

holders of record for the QuadGuard system are Michael H. Oberth and John V. 

Machado and both, Mr. Oberth as well as Mr. Machado, were employed by EAS. The 

associated United States Patent Office patent application numbers (5,797,592 & 

5,733,062) are assigned to Energy Absorption Systems, Inc. I Trinity Industries, Inc. 

EAS sponsored certain crash tests of the QuadGuard® system; such tests were 

conducted by E-Tech Testing Services, an independent, wholly-owned subsidiary of 

THP. E-Tech Testing Services is an International Standards Organization ("ISO") 

17025 accredited laboratory with American Association for Laboratory Accreditation 

(A2LA) Mechanical Testing certificate 989.01. Full-scale crash testing on the 

QuadGuard® system was performed in accordance with testing criteria, as set forth by 

the National Cooperative Highway Research Program ("NCHRP") in the NCHRP Report 

350 (1993). 
Please advise if further information is required by the FHWA. We look forward 

to continuing to work with the FHWA in regards to the QuadGuard® and other Roadside 

Safety Hardware. 

Sincerely, 

Bret Eckert, P.E. 

Engineering Applications Manager 

Trinity Highway 

Office 916-644-9131 

bret.eckert@trin.net 
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