AV Safety Evaluation Report Requirements in AV START Act

Author: Robert Fischer, GTiMA President & Heath Davis-Gardner, Technology and Digital Culture Editor | Date: October 11, 2017

The AV START Act, which unanimously moved out of committee and is now headed for a vote in the Senate (a companion version has already passed the US House), has laid out in detail what OEMs must certify in terms of safety for vehicles before introducing them into interstate commerce for testing purposes).

This update is intended to summarize exactly what aspects of vehicles OEMs must certify for safety if and when the act passes (as all indications say it will).

Each report will have to describe in detail how the manufacturer is “addressing, through a documented assessment, testing and validation for each of the subject areas” listed below.

System Safety
*Assurance that hardware and software function as intended
*Means by which “unreasonable risks to safety” would be mitigated in the event of a malfunction
*The vehicle’s sense of “objects, motorcyclists, bicyclists, pedestrians and animals in or crossing the path of travel” via the AV system.

Data Recording – the collection by the AV of information and incident and crash data must:
*Record the occurrence of malfunctions, disengagements, degradations, or failures
*Aid in the analysis of the cause of any of the above issues
*Enable efforts to “work with other entities to address data recording and sharing”
*Comply with collection and sharing requirements laid out in the FAST Act (Public Law 114-94).

*“The minimization of cybersecurity risks” must be outlined in the report, as must include, to the DOT, “exchange of information about any vulnerabilities discovered from field incidents, internal testing, or external security research.”

Human-machine Interface – report must describe:
*The methods of informing human driver/operator regarding the AV system’s functioning, and warning when AV systems are suboptimal
*For Level 3 vehicles, methods to address driver reengagement when AV systems fail
*The use of human-machine interface by people with disabilities – law suggests visual, auditory, or haptic displays, “or other methods.”

*Report must outline “practicable protection for all occupants” given any seating configuration possible in the vehicle.

*Report must detail the capabilities and limitations of the AV system.

Post-Crash Behavior
*Report must describe how the vehicle will behave if sensors or critical systems are damaged in a crash.

Accounting for Applicable Laws
*Report must describe how the AVs will account for all applicable traffic laws and rules of the road, “based on operational design domain”

Automation Detection – report must describe:

*The expected operational design domain in which the AV is designed to operate, including any roadway and infrastructure assets required for its operation, “such as roadside equipment, pavement markings, signage, and traffic signals,” and how the vehicle will respond “if that operational design domain unexpectedly changes.”
*The AV’s expected object and event detection and response capabilities, including behavioral competencies and crash avoidance capability.
*The ability of the AV system to “transition to a minimal risk condition” when malfunctions happen.
*The performance of the vehicle through all testing developed and/or implemented by the manufacturer, including simulation, test-track and on-road testing.

NOTE: This is still not yet law, but indications are that the divisive amendments that were removed from the bill will be taken up separately and that the US House will accept the Senate bill in committee. However, any updates and revisions will be reported, if necessary.

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