Proposal to amend explanatory text for UNR paragraph 3.2.3. (b) to clarify that the manufacturer should explain how they determine and apply the concept of the safety level of the ADS being at least to the level of a competent and careful human driver, accounting for national specificities, and that there may be different approaches used in applying this concept, including reference driver based approaches and behaviour-based approaches.
Proposal to amend guidance on continuous improvement processes in para. 7.1.8.2. by inserting text stating that post-deployment safety analyses are systematically performed for all occurrences; however, their conclusions do not necessarily result in the identification of a corrective action from the manufacturer, modifying text to state that not all identified corrective or preventive actions need to be implemented in order to close an occurrence, and replacing text to state decisions on what to address and how are based on an overall assessment of the consequences and the impact of implementing a change.