Any company testing on public roads should conform to the industry standard for road testing safety: SAE J3018.
When AV road testing first started, it was common for testers to claim that they were safe because they had a "safety driver." However, as was tragically demonstrated in the Tempe AZ testing fatality in 2018, not all approaches to safety driving are created equal. Much more is required. Fortunately, there is an SAE standard that addresses this topic.
SAE J3018_202012 "Safety-Relevant Guidance for On-Road Testing of Prototype Automated Driving System (ADS)-Operated Vehicles" (https://www.sae.org/standards/content/j3018_202012/ -- be sure to get the 2020 revision) provides safety relevant guidance for road testing. It concentrates on guidance for the "in-vehicle fallback test driver" (also known informally as the safety driver).
The scope of J3018 includes:
- Fallback test driver training (classroom, simulation, track, on-road)
- Workload management
- Selection of test routes
- Pre-trip protocol (checklist, inspection)
- Test driver monitoring
- Test driver post-test debrief
- Incident response protocol
AV testers should be conform to J3018 to ensure that they are following identified best practices for safety driver training and effectiveness. Endorsing this standard will avoid a DOT having to create their own driver qualification and training requirements.
Taking a deeper look at J3018, it seems a bit light on measuring whether the safety driver is actually providing effective risk mitigation. Rather, it seems to implicitly assume that training will necessarily result in acceptable road testing safety. While training and qualification of safety drivers is essential, it is prudent to also monitor safety driver effectiveness, and testers should be asked to address this issue. Nonetheless, J3018 is an excellent starting point for testing safety. Testers should be doing at least what is in J3018, and probably more.
J3018 does cost money to read, and the free preview is not particularly informative. However, there is a free copy of a precursor document available here: https://avsc.sae-itc.org/principles-01-5471WV-42925L3.html that will give a flavor of what is involved. That having been said, any DOT guidance or requirement should follow J3018, and not the AVSC precursor document.
In addition to following J3018, the safety-critical mechanisms for testing should be designed to conform to the widely used ISO 26262 functional safety standard. (This is not to say that the entire test vehicle -- which is still a work in progress -- needs to conform to 26262 during testing. Rather, that the "Big Red Button" and any driver takeover functions need to conform to 26262 to make sure that the safety driver can really take over when necessary.)
For cargo vehicles that will deploy without drivers, J3018 can still be used by installing a temporary safety driver seat in the vehicle. Or the autonomy equipment can be mounted on a conventional vehicle in a geometry that mimics the cargo vehicle geometry. When the time comes to deploy without a driver physically in the system, you are really testing an autonomous vehicle with a chase car or remote safety supervisor, covered in a following section on testing without a driver.
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