Consumer Reports has filed comments with the National Highway Traffic Safety Administration on a proposed United Nations regulation for automated driving systems, urging U.S. regulators to adopt clear, enforceable safety standards.
In the submission, William Wallace, director of safety advocacy at Consumer Reports, writes that “when an ADS is engaged, it is performing the entire dynamic driving task and is therefore acting as the driver.” He adds that automated driving systems “should be evaluated as drivers, not merely as vehicle features.”
Wallace points to the draft regulation’s reference to performance comparable to a “competent and careful human driver,” stating that “such a comparison must be supported by clear, objective and measurable safety criteria.”
He supports provisions requiring systems to operate safely within their operational design domain, writing that automated vehicles must be able to “follow traffic laws, detect and respond to roadway conditions, appropriately respond to priority vehicles, avoid unreasonable interference with traffic flow and prevent crashes.”
On system failures and operational limits, Wallace states that rules requiring a transition to a “minimal risk condition” are essential to ensuring safety when an automated driving system encounters conditions it cannot handle.
The submission also addresses safety management systems and safety cases, warning that “safety cases should not rely solely on manufacturer assertions” and calling for “independent verification and validation or regulator-led evaluation.”
Regarding oversight after deployment, Wallace writes that crash reporting must include information such as “whether the ADS was operating outside of its intended conditions, whether a system failure occurred, whether the vehicle requested human intervention or transitioned to a minimal risk condition and whether remote assistance was utilized.”
He further states that “exposure data, including miles traveled with ADS engaged, is necessary to meaningfully assess safety performance.”
The filing concludes that compliance with federal motor vehicle safety standards must remain a baseline requirement and that exemptions should be “limited and subject to transparent review.”
