Proposal to improve the interpretation of para. 8.1.5.1. concerning the scope and contents of the manufacturer’s SMS safety policy.

Proposal to improve the interpretation of para. 8.1.5.1.(a) concerning the definition of the principles and objectives upon which the SMS is built, operated, and maintained.

Proposal to improve the interpretation of para. 8.1.5.1.(b) concerning the general recognition of the inherent risks of ADS-related activities throughout their life cycle, including the risks of the parties involved.

Proposal to improve the interpretation of para. 8.1.5.1.(c) concerning the organizational structure and the safety governance elements and their appropriateness for the needs of the organisation.

Proposal to improve the interpretation of para. 8.1.5.1.(e) the description of the means/approaches to engage people within the organisation in the culture of safety.

Proposal to delete the requirement that competence is expected to be actively developed and maintained through structured training and insert that this point focuses on the existence and maintenance of SMS training plans to support competence for the SMS management in para. 8.1.6.1.(b).

Proposal to revise the guidance text in para. 8.1.8.1.(c) by deleting “This element ensures the existence of effective communication channels, both internally and externally, to support awareness and information sharing.” and inserting “This point focuses on the existence of communication channels, both internal and external, to support awareness and information sharing.” The proposal follows comments received in the 18th ADS Workshop where discussion of the SMS section in a dedicated small drafting group was requested, and the current text aims at streamlining the text.

Based on ADS-21-68/Rev.1, amend para. 3.2.3.(b) to clarify that the regulation requires the safety level of ADS to be at least to the level of a competent and careful human driver as a general concept and technology-neutral comparator, that manufacturers should explain how they determine and apply this concept accounting for national specificities including those that might arise in relevant cases, that different approaches or combinations of approaches may be used varying depending on the safety concept, claims and argument structure, and approach to safety assessment, that no single approach is presumed better, that manufacturers may use more than one approach, that driver population reference data sets should be subject to appropriate selection, processing and interpretation, and to provide non-exhaustive examples of reference driver based approaches and behaviour-based approaches.