Automated Driving Systems
2.0: A Vision for Safety
Revision of a currently approved collection
No
Regular
05/28/2021
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 – via industry best practices, their own best practices, or
other appropriate methods – 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
NHTSA’s 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
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