1200 New Jersey Ave., SE

 Washington, D.C. 20590

December 23, 2011

FHWA: HSST: NArtimovicht: sf: x68568:12/21/11

File: s: //directory folder/HSST/Artimovich/ WZ54A_Ross_Lightweightdrum.docx

HSST: cc: NickArtimovicht Will Longstreet

In Reply Refer To:

HSST/ WZ-54A

Henry Ross

Director of Government Relations

Plasticade

7700N. Austin Avenue

Skokie, Illinois 60077

Dear Mr. Ross:

This letter is in response to your request for the Federal Highway Administration (FHWA) to 

review a roadside safety system for eligibility for reimbursement under the Federal-aid highway 

program. 

Name of system: Lightweight plastic drums with warning lights

Type of system: Work Zone Channelizing Traffic Control Device

Test Level: NCHRP Report 350 Test Level 3

Testing conducted by: N/A

Date of request: March 7, 2011

Date initially acknowledged: March 7, 2011

Date of completed package: October 5, 2011

Decision:

The following device is eligible, with details provided below:

• Lightweight plastic drums with warning lights

Based on a review of the analysis submitted by the manufacturer certifying the device described 

herein meets the crashworthiness criteria of the National Cooperative Highway Research 

Program (NCHRP) Report 350, and input from the Texas Transportation Institute, the device is 

eligible for reimbursement under the Federal-aid highway program. Eligibility for 

reimbursement under the Federal-aid highway program does not establish approval or 

endorsement by the FHWA for any particular purpose or use. 

The FHWA, the Department of Transportation, and the United States Government do not 

endorse products or services and the issuance of a reimbursement eligibility letter is not an 

endorsement of any product or service.

Requirements

Roadside safety devices should meet the guidelines contained in the National Cooperative 

Highway Research Program (NCHRP) Report 350 or the American Association of State 
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Highway and Transportation Officials’ Manual for Assessing Safety Hardware. The FHWA 

Memorandum “Identifying Acceptable Highway Safety Features” of July 25, 1997 provides 

further guidance on crash testing. 

Description

FHWA Letter WZ-54, dated September 15, 2000, included plastic drums with warning lights as 

Category I devices. In Section C, Drums with Warning Lights, there is a table that describes 

design features of drums in common use at the time this memo was issued. Features included 

dimensions, materials, weights, etc. The weight range for drums is 4.5 kg to 7.3 kg. Some states 

and government agencies are interpreting this table as specifying minimums and maximums for 

these devices. Since 2000, several drum manufacturers have decreased the wall thickness at the 

lower portion of their drums in order to facilitate easier stacking, without compromising the 

thickness of the handle or the effective light mounting capability of the drum. In addition, crash 

testing under MASH criteria on lighter weight devices with lights has shown successful results. 

The critical issue is the attachment of the light to the device. As long as this attachment remains 

consistent and viable, the weight of the device holding it can vary outside of the weight ranges 

originally contained in the table.

You requested that drums lighter than 4.5 kg be considered eligible for reimbursement. We 

contacted Dr. Roger Bligh of the Texas Transportation Institute regarding this issue as TTI 

conducted the early crash testing of drums with warning lights attached. Dr. Bligh concurred that 

reduction in the mass of the drums below 4.5 kg would not have an adverse affect on the 

crashworthiness of drums, provided that the strength of the part of the drum where lights are 

connected was not changed.

Findings

We concur that plastic drums conforming to the MUTCD Section 6F.67 weighing up to 7.3 kg 

are eligible for reimbursement and should be installed under the range of conditions tested, when 

such use is acceptable to a highway agency. Drums with Type A or C warning lights firmly 

affixed to adequately strengthened mounts using vandal resistant hardware may be self-certified 

as crashworthy by the vendor. 

Please note the following standard provisions that apply to FHWA eligibility letters:

• This finding of eligibility is limited to the crashworthiness characteristics of the systems 

and does not cover their structural features, nor conformity with the Manual on Uniform 

Traffic Control Devices.

• Any changes that may adversely influence the crashworthiness of the system will require 

a new letter.

• Should the FHWA discover that the qualification testing was flawed, that in-service 

performance reveals unacceptable safety problems, or that the system being marketed is 

significantly different from the version that was crash tested, we reserve the right to 

modify or revoke this letter.

• You will be expected to supply potential users with sufficient information on design and 

installation requirements to ensure proper performance.

• You will be expected to certify to potential users that the hardware furnished has 

essentially the same chemistry, mechanical properties, and geometry as that submitted for 
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review, and that it will meet the crashworthiness requirements of the FHWA and the 

NCHRP Report 350.

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

WZ-54A and 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 at our office 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. 

The finding of eligibility is limited to the crashworthiness characteristics of the candidate 

system, and the FHWA is neither prepared nor required to become involved in issues 

concerning patent law. Patent issues, if any, are to be resolved by the applicant.

Sincerely yours,

Michael S. Griffith

Director, Office of Safety Technologies

Office of Safety