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 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.
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 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 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.”
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).