Proposal concerning “detected objects” and data element precision for the ADS regulation provisions on DSSAD.

Proposal concerning “detected objects” and data element precision.

Proposal to add retrieval of DSSAD time-stamp data elements recorded for at least the last 30 seconds before the last setting of the event flag “Event Data Recorder (EDR) trigger input” alongside EDR data through the same interface, add provisions for retrieval when no such event occurs within the last 30 seconds, add provisions to replace date and time with relative time information when required by national or regional law, and add detected collision by Automated Driving System as an EDR trigger for UN R160 and UN R169.

Proposal to update the explanation on reportable occurrences in Annex 1 (GTR) and 3 (UNR). The revision refines language in the requirement describing the manufacturer’s Safety Management System by removing “expected” to avoid implying obligation and clarifying the link between occurrence monitoring, reporting, analysis, system updates, improvements, and continuous improvement processes.

Proposal to clarify EDR provision in Annex on thresholds. For vehicle categories M₂, M₃, N₂, and N₃, the revised text clarifies that UN Regulation No. 169 does not include a representative delta V threshold. The manufacturer could determine their own delta-V trigger for a critical occurrence, including one based on a subset of EDR triggers, with no obligation to do so.

Proposal to amend para. 8.1.5.1. (ADS UNR) of the audit of the safety policy guidance: Change “may state” to “states,” “may address” to “addresses,” and “may therefore describe” to “therefore describes.” The rationale states that using “may” in the interpretation paragraphs seems inappropriate for explaining regulatory intention, and present tense better suits these requirements.

This document presents the status of the Guidance and Interpretation document for UN Regulation and GTR ADS, submitted by the OPI on ISMR provisions. It outlines closed topics including clarification on EDR trigger for critical occurrence, confidentiality and publication of information, and guidance on short-term, periodic templates and SPIs. Ongoing work addresses guidance on occurrences with examples of situations and metrics for ADS operation outside its ODD, and guidance for development of scenarios derived from ISMR activities.

Proposal to explain paragraph 8.3.2.1.2. The revision clarifies that coverage can be evaluated based on the following items and their interdependencies: Operational Environment, Behavioural competency, Scenario-type/category, and Rules of road compliance. A footnote acknowledges that no single item alone can robustly document coverage.

Proposal to explain para. 7.3.2.14. The revised text simplifies the definition of ‘sufficient’ to refer to the scope of tests performed on the fall-back response. With respect to scenarios, the manufacturer is encouraged to describe reasoning behind scenario choice and justification for the overall number chosen, acknowledging that scenario diversity depends on intended use case and operational design domain. References to user numbers and statistical methods for sample size assessment have been removed.

Proposal to explain para. 8.3.2.4.1.4. The revised text divides guidance between ADS users and other road users. For ADS users, representativeness means including a range whose behaviours, skills, and characteristics reflect those reasonably expected to use the ADS, with testing not limited to engineers. For other road users, representativeness means capturing a sufficiently broad range of real-world behaviours and characteristics relevant to the ODD. The revised proposal also addresses statistical significance, encouraging manufacturers to provide calculations explaining their choice of participant numbers and underlying assumptions.

Proposal to explain para. 8.3.3.1.1. The revised text clarifies that relevant standards supporting the assessment of laboratories could include ISO/IEC 17025 Testing and calibration laboratories, which sets requirements for competence, impartiality, and consistent operation. Applied to ADS testing, it ensures measurements are traceable, validated, and reproducible so results are technically reliable and defensible for approval/certification purposes. However, there is no obligation for the manufacturer or third-party organization involved in the testing to be accredited according to ISO/IEC 17025.

Proposal to explain para. 8.3.3.1. of the draft UN Regulation. The proposal addresses residual comments concerning wording used to derive scenarios for confirmatory testing by removing terminology not used in the regulation to avoid mis-interpretations. Confirmatory testing scenarios depend on the ADS feature, its ODD, and safety case scenarios. When selecting scenarios, the assessor may consider the ADS system description and its safety concept, and the safety claims presented in the safety case. Confirmatory testing may be undertaken using virtual testing, expected to be within the scope and capability of the toolchain being used, and can be within, at the boundary of or outside the ODD.

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.