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 guidance text in para. 8.1.6.1.(d) to delete the statement that the intention is to ensure safety promotion contributes to ongoing learning and improvement, reinforcing the adaptive nature of the SMS, and insert revised text stating that this point focuses on continued evaluation contributing to ongoing learning so that the SMS remains effective, allowing an adaptive nature through modification and adaptation supported by safety recordkeeping.

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 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.

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.