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Presents the SAE J3134 review of Automated Driving System (ADS) Marker Lamp Requirements

Proposal to revise the explanation for para. 8.3.3.1 to clarify the relationship between assessment of the manufacturer’s testing under 8.3.2 and confirmatory testing. The revision adds language specifying that during assessment, the assessor can determine the need for additional scenarios or variations and shall convey this information to the manufacturer requesting additional test evidence under agreed upon protocols. The revision changes “trustworthy” to “accurate” and specifies that confirmatory testing verifies the accuracy of the manufacturer’s testing, with the exception of real-world testing that cannot be precisely replicated.

Proposal to clarify MRC for ADSF-2 in para. 6.1.5.4.1. The revised text corrects the assertion that ADSF-2 features can meet a lower standard for MRC because of fallback user presence in ADSF-1. It clarifies that ADSF-2 features do not include an ADS fallback response requiring a fallback user, though such features may be present in vehicles with human users. Both ADSF-1 and ADSF-2 features must aim to bring the ADS vehicle to a stop in a safe location complying with traffic rules following ODD exit.

Proposal to revise Annex 3, item 2 regarding “ADS failure to achieve a mitigated risk condition when necessary.” The revised text maintains the four bullet points describing when such occurrence is expected to be reported when an MRC is required. The rationale states the regulatory text does not require reporting when an MRC is achieved but in an unsafe stop location, which is not defined in the regulation, nor when an MRC is achieved but conflicts occur during the MRC.

Proposal to delete from the interpretation of failures to meet ADS requirements under para. 6 in Annex 3 the items “Collisions” and “Deviation from Remote Interaction/Intervention as described in the Safety case,” as these are not ADS requirements under para. 6, and collisions are otherwise reportable under the critical occurrences criterion.

Proposal to insert provisions clarifying that when assessing manufacturer’s testing activities under paras. 8.3.2.1.1, 8.3.2.1.2, 8.3.2.2.2, and 8.3.2.2.3, the approval authority or designated technical service may identify situations or scenarios not included in manufacturer’s test evidence, convey that information to the manufacturer, and request additional test evidence covering those situations or scenarios under agreed upon protocols, with the assessor able to determine the need for variations to tested scenarios or conditions to verify that the manufacturer’s evidence is representative and able to support the safety case, where variations may include adjustments to initial conditions, parameter ranges, or environmental assumptions within the bounds or at the boundaries of the declared ODD but may also consider behaviour at ODD exit or outside the ODD, with such variations expected to be reasonable and compatible with the limitations and abilities of the toolchains and allow comparison with initial results provided by the manufacturer or be assessable against the expected behaviour of the system.

Proposal to clarify section 6.1.2.1 regarding crash causation. During approval process, when collisions involve the ADS during the manufacturer’s real-world or confirmatory testing, a root cause analysis is required and an explanation provided. Where the ADS is determined to have played a role in causation, the manufacturer will provide evidence of how related causal factors have been addressed in the final ADS prior to approval. Post-deployment collisions are covered by the ISMR process taking into account the applicable law of the country in which the collision occurred.

Proposal to revise explanation of Annex 3 in the draft guidance document. The change proposes language clarifying that performance issues constitute an unreasonable risk to safety only when deviations, degradations, or limitations in ADS capabilities, based on analysis of their frequency and severity, present an unreasonable risk within the declared ODD. The revision specifies that listed factors are examples for consideration in determining whether an unreasonable risk exists but do not necessarily constitute such a risk themselves.