FHWA Response to the Work Plan
11/4/14 communication from Tony Furst, Associate Administrator for Safety, FHWA
In response to Trinity's 10/31/14 test plan submission.
These items cover the response from FHWA regarding the test plan you submitted on 10/31/14. Our understanding of the conversation we had on the morning of 11/4/14 is included in italics the items below. As discussed, we look forward to your response to items 1a, 2a, 2b, 3a and 7 by COB on Wednesday, 11/5/14.
- The proposed test plan begins on 11/17/14 and concludes on 1/15/15. FHWA would like Trinity to explore options for accelerating that timeline, potentially to conclude before the end of the calendar year. Trinity will discuss options for accelerating the timeline for the tests with Southwest Research Institute and inform FHWA of options.
- FHWA wants to confirm that we will receive the summary test reports for the ET27 test series as soon as possible after the completion of the final test in that series - same for the ET31 tests. Trinity confirmed that is correct and that the summary reports would be equivalent to those for a device seeking an initial determination of eligibility.
- FHWA needs confirmation that the current production unit dimensions of the ET-Plus that are proposed for testing are an exact match to the dimensions tested in 2005 and 2010. Trinity will provide.
- Our letter asked for detailed product schematics for the system and the head. The schematic for the head does not have sufficient detail. We need full detailed product schematics for the head including all internal and external dimensions. Trinity informed that the fabrication specifications are confidential business information. They will provide and clearly identify the information that is confidential business information.
- Devices to be tested.
- FHWA has received reports that the ET-Plus being sold on the market today has different internal dimensions than what the technical plans indicate. FHWA wants the devices that will be crash tested to be pulled from the replacement/spare parts inventory of a State DOT. Trinity expressed concerns with the chain of custody of devices pulled from field inventory; this issue needs to be mitigated. FHWA will take under advisement Trinity's request to see the information regarding the internal dimensions measured in the field that has been provided to FHWA.
- Test vehicles to be used.
- FHWA needs to know what test vehicles (make, model, and year) Trinity is proposing to use. FHWA understand that there are challenges in finding vehicles on today's market that were commonly used for NCHRP 350 testing. However, rather than potentially using older vehicles, FHWA believes it's best to use vehicles that are 5 to 7 years old that have the key properties that meet the 350 requirements. Once Trinity has identified the vehicles and evaluated their properties relative to NCHRP350, they will inform FHWA of the vehicles and Trinity's rationale for their use. Trinity will provide information on the test vehicles to be used as soon as possible.
- In FHWA's letter on 10/21/14 it states that FHWA personnel and consultants should be present at the crash tests. The test plan only references FHWA observers. FHWA intends to bring independent experts, members of AASHTO, and State DOT representatives along with FHWA personnel. FHWA will provide Trinity, in advance, with a list of FHWA personnel and those we wish to invite to attend the crash tests. Trinity agrees, is primarily concerned with impartiality, and will inform FHWA if they have concerns with any of the individuals on FHWA's list.
- Additional information.
- FHWA's letter of 10/21/14 (para. 5 of the attachment) calls for additional information by 11/11/14. In what form should FHWA expect this material to arrive by that date. Trinity will provide the requested information by that date. Given the volume of data (videos, etc.) it will be sent via a mail courier. Trinity advised that the R&D crash tests on the flared version of the ET-Plus system were owned by Texas Transportation Institute and FHWA should contact Texas A&M University to acquire those test videos and results.
- Pending FHWA's review of the additional information provided by 11/11/14 and other information that has been brought forward, FHWA may have additional requirements. FHWA will keep Trinity advised. Acknowledged.
- The test plan that was submitted is labeled 'highly confidential' in its entirety. FHWA will be releasing the test plan to the public. If there is business confidential information in the plan, that specific information needs to be clearly identified as such. Trinity will provide a complete test plan to FHWA including any business confidential information and a version of the test plan that has the confidential business information redacted.