Proposal to improve the interpretation of para. 8.1.6.1.(b) concerning verification that the risk-management activity is not limited to the ADS itself but includes risk arising from organisation/people which can affect the SMS effectiveness or the safety of the ADS.

Proposal to modify para. 8.1.7.1.(h) to replace “aims to ensure that” with “focuses on”, replace “Assessment of how organizations coordinate” with “Assessment that organizations coordinate”, delete “and product reviews” from the list of change management triggers, and delete “the approach and output from various” before “monitoring procedures” and delete “including operational data, safety reports and performance indicator” from the examples of monitoring procedures.

Proposal to modify the safety risk management definition by replacing “the core” with “an”, changing “that supports” to “described in”, deleting “and the intended results of the Organization, as well as the effectiveness of other organizational processes”, capitalizing “Organization” to “organization”, and removing the comma after “Organization”. The term safety risk management restricts itself to the management of safety risks without consideration of factors such as financial, legal, economic, or reputational risks.

Proposal to amend the interpretation of para. 8.1.5.1.(d) to replace “a key” with “an”, delete “effective”, and insert “processes” before “of the SMS”. The proposal streamlines guidance text on SMS safety policy to improve clarity in describing how safety policy demonstrates management commitment to safety through approval by the accountable executive and supports promotion of safety and continuous improvement of the SMS.

DSSAD data, whether stored on or off the vehicle, shall be readily available and retrievable through an electronic communication interface that complies with a publicly available standard, with internationally recognized standards recommended to promote interoperability. Data elements concerning activation and deactivation of the feature shall be available via the vehicle’s information display or user interface where controls related to manual performance of the DDT are provided, with access to timestamps subject to restrictions ensuring compliance with data protection requirements.

The Informal Working Group on Automated Driving Systems identified topics for future consideration, categorised into four lists: items not addressed within original versions of the GTR/UNR; existing items requiring amendment or improvement; items relating to operational implementation; and other items. List 1 includes consistent Operational Design Domain description, external Human-Machine Interface provisions, and connectivity considerations. List 2 includes remote assistance, ADS to ADAS transitions, Data Storage Systems for Automated Driving, deactivation processes, and In-Service Monitoring and Reporting. List 3 addresses improvements from drafting interpretation documents, road safety agents, mutual recognition provisions, system updates, and Separate Technical Unit approval. List 4 addresses text streamlining. A Guidance and Interpretation Document is expected. Appendix 1 provides a work schedule beyond June 2026.

Proposal to replace text explaining that the ADS IWG did not reach consensus on definitions with clarification that remote intervention and remote interaction were not intended to convey different meanings in the regulation, both covering cases where the ADS requires support for tactical functions while continuing to perform the entire dynamic driving task, note that this aspect of ADS is a developing area, and include references to SAE J3016-2021, EU 2022/1426, the Automated Vehicle Safety Consortium Best Practice for ADS Remote Assistance Use Case (Nov. 27, 2023), and the upcoming ISO/PAS 26361 standard.

Proposal to improve guidance on para. 8.1.8.1. which focuses on aspects that support safety and safety culture such as people, competencies, and communication.

Proposal to improve the interpretation of para. 8.1.6.1.(d) on continued evaluation contributing to continuous learning so that SMS remains effective through modification and adaptation.

Proposal to add resources providing guidance on Safety Performance Indicators. The added resources include J3237, Dynamic Driving Task Assessment (DA) Metrics for Automated Driving Systems; AVSC00006202103, Automated Vehicle Safety Consortium (2021) Best Practice for Metrics and Methods for Assessing Safety Performance of Automated Driving Systems (ADS); AVSC00008202111, Automated Vehicle Safety Consortium (2021) AVSC Best Practice for Evaluation of Behavioural Competencies for ADS-Dedicated Vehicles (ADS-DVs); SAE J2944, Operational Definitions of Driving Performance Measures and Statistics; and SAE J3197, Automated Driving System Data Logger.

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.

Proposal to delete text stating “The requirement highlights that competence is expected to be actively developed and maintained through structured training.” and insert text stating “This point focuses on the existence and maintenance of SMS training plans to support competence for the SMS management” as guidance on interpreting the requirement in para. 8.1.8.1.(b).

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.© concerning the organizational structure and the safety governance elements and their appropriateness for the needs of the organisation.

Proposal to remove brackets around GB/T 34590 Road vehicles – Functional safety and GB/T 43267 Road vehicles – Safety of the intended functionality in para. 8.1.5.1. References for Implementation. The approval authority or its designated technical service shall verify that the safety policy covers definition of principles and objectives, general recognition of inherent risks of ADS-related activities throughout their life cycle, organisational structure and safety governance elements, evidence of commitment to safety, and description of means/approaches to engage people within the organisation in the culture of safety.

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 revise the guidance text in para. 8.1.8.1.© 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.

Proposal to improve the guidance to read “This point focuses on management of qualification and experience for roles responsible for making decisions that affect safety so there is appropriate level of competence to perform their duties.”