Automated Driving Systems 2.0: A Vision for Safety
Revision of a currently approved collection
No
Regular
05/28/2021
table that charts list comparision
Requested
Previously Approved
36 Months From Approved
05/31/2021
20
60
12,000
86,100
0
8,610,000
This ICR is for a voluntary disclosure of information to the public by entities involved in the testing and deployment of Automated Driving Systems (ADSs). The entities engaged in ADS development and testing may demonstrate how they address â via industry best practices, their own best practices, or other appropriate methods â the safety elements contained in the Voluntary Guidance section of Automated Driving Systems 2.0: A Vision for Safety by publishing a Voluntary Safety Self-Assessment (VSSA). The VSSA is intended to demonstrate to the public (particularly States and consumers) that entities are: (1) considering safety aspects of ADSs; (2) communicating and collaborating with DOT; (3) encouraging the self-establishment of industry safety norms for ADSs; and (4) building public trust, acceptance, and confidence through transparent testing and deployment of ADSs. It also allows companies an opportunity to showcase their approach to safety, without needing to reveal proprietary intellectual property. Disclosure of information in the VSSA would be publicly accessible and foreseeably accessed by members of the public, State stakeholders, and consumer-based stakeholders. NHTSA anticipates the respondents for the information collection would provide the VSSA once every three years.
This extension includes a revision to the burden calculations. Based on NHTSAâs observations of the current collection, NHTSA estimates that while there will be 60 respondents to this collection, they will not create and disclose a new VSSA each year. Instead, NHTSA now estimates that the 60 respondents will produce a new VSSA every three years. Therefore, NHTSA has lowered the estimated number of respondents to 20 per year. NHTSA has also eliminated the burden associated with addressing the safety elements in the Voluntary Guidance but maintained the burden associated with development and publication of the VSSA. This results in a substantial reduction in burden hours and burden hour cost. NHTSA now estimates the total burden associated with disclosure recommendations via a VSSA would be 600 hours per respondent with 20 respondents disclosing VSSAs per year (60 total respondents disclosing once per three years) for a total burden of 12,000 hours per year. This is a decrease of 74,100 hours per year. Additionally, there is a decrease in costs of $8,610,000 because NHTSA incorrectly included $8,610,000 of labor costs in response to question 13 in the last ICR. NHTSA estimates that respondents will not incur any costs beyond hourly labor costs.
US Code:
49 USC 30101
Name of Law: Motor Vehicle Safety Act of 1966
NHTSA estimates the total burden associated with disclosure recommendations via a VSSA would be 600 hours per respondent with 20 respondents disclosing VSSAs per year (60 total respondents disclosing once per three years) for a total burden of 12,000 hours per year. This is a decrease of 74,100 hours per year. Additionally, there is a decrease in costs of $8,610,000 because NHTSA incorrectly included $8,610,00 burden labor costs in response to question 13 in the last ICR.
It is important to note that the Automated Driving Systems 2.0: A Vision for Safety was published on September 15, 2017, and is intended to be updated as appropriate. That policy has not been updated to date and thus there are no changes in the Voluntary Guidance or discussion of the VSSA. However, NHTSA is adjusting the estimate of burden hours in this information collection extension request.
In the previous information collection request, NHTSA separated the information collection into two parts: the documentation suggested in the Voluntary Guidance of ADS 2.0 and the public disclosure of information via the Voluntary Safety Self-Assessment. Upon publication of ADS 2.0, the Agency anticipated an l increase in burden associated with the documentation suggested by the Voluntary Guidance to be incurred by entities. However, much of this documentation was already called for by both industry consensus standards (such as ISO 26262) or represented good systems-engineering practices. During the collection period since 2017, NHTSA has determined there to be no increased documentation citing how an entity addressed the safety elements in the Voluntary Guidance. NHTSA does not believe that any entity is documenting its safety efforts solely for the purpose of the VSSA and public disclosure.
As the effort is voluntary, entities opting to consider safety elements are doing so as part of regular business operations and those not considering safety elements are not incurring burden nor penalized for such. Therefore, the 835 burden hours per respondent associated with additional documentation for consideration of safety elements has been removed from the estimate for the extension of this information collection.
The second change to the information collection is the frequency of collection. During the three years of the current information collection, NHTSA is not aware of any respondent that has updated its VSSA. Thus, frequency of disclosing a VSSA is as needed, with a maximum of once per three years as evidenced by the data. This is a change from the previous information collection request, which estimated frequency at once a year.
$1,126
No
No
No
No
No
No
No
Debbie Sweet 202 366-7179
Reginfo record details
No
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
ADS 2.0.pdf
PRA_SS_PartA_VSSA_2127-0723_051121_Final.docx
Automated Driving Systems 2.0: A Vision for Safety