Page 45 - Occupational Health & Safety, March 2018

The request explains that almost all of the agency’s more than 60 existing Federal Motor Vehicle Safety Standards, known as FMVSS, were developed “well before vehicles with ADS became a practicable possibility.” As a result, the performance requirements and test procedures laid out in many FMVSS assume there will be a human driver in a vehicle’s left front seat who needs certain controls and displays in order to do the driving.
“A further and even more basic assumption is that there will be at least one occupant in each vehicle,” it says. “In the case of ADS delivery vehicles without manual driving controls, this assumption may prove incorrect. If, instead, a vehicle is designed so that only an ADS can drive it and vehicle designers modify the passenger compartment to take advantage of the flexibility afforded them if a human driver is not needed, then many of those assumptions will likely be invalid for that vehicle, and some may actually be prob- lematic from a testing perspective.”
NHTSA then listed a few potential problems and asked com- menters to identify others. The ones NHTSA listed include these:
■ If the FMVSS can’t specify where controls and displays are located, it is not clear for which occupant or seating position they must be visible, or even if they’re necessary at all.
■ Are current performance requirements still needed in the standards? Would occupants still need warning telltales and other displays if they have no means of driving their vehicles, for ex- ample? And what are the safety ramifications of having no telltales before or during trips?
■ If future ADS vehicles have no means of human control, how can DOT and vehicle manufacturers conduct compliance tests, such as for stopping distance, that currently are conducted by human drivers on test tracks?
■ FMVSS No. 126, Electronic stability control systems for light vehicles, requires the use of an automated steering machine that depends on a vehicle’s steering wheel during compliance test- ing. How should the standard be amended to allow for stability control testing of ADS vehicles that have no steering wheel?
So there will be no misunderstanding among stakeholders or the public, NHTSA explains in the document that no current FMVSS or any other kind of legally binding standard contains provisions that are designed to address the self-driving capability of a motor vehicle, and further, there is nothing in current FMVSS to prohibit ADS. “Likewise,” it says, “nothing in those standards poses testing or certification challenges for vehicles with ADSs so long as the ve- hicles have means of manual control and conventional seating.”
The FMVSS must be “objective, practicable, and meet the need for safety,” according to the Vehicle Safety Act, so the agency in some instances will require research in order to develop revised test procedures and performance criteria. The request for comments is intended to help define the needed research and establish priorities in conducting it, NHTSA says.
New NHTSA Research Under Way
NHTSA says in the document that it began evaluating the FMVSS
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