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Safety Recommendation Details

Safety Recommendation H-17-038
Synopsis: At 4:36 p.m. eastern daylight time on Saturday, May 7, 2016, a 2015 Tesla Model S 70D car, traveling eastbound on US Highway 27A (US-27A) west of Williston, Florida, struck a semitrailer powered by a 2014 Freightliner Cascadia truck tractor. At the time of the collision, the truck was making a left turn from westbound US 27A across the two eastbound travel lanes onto NE 140th Court, a local paved road. The car struck the right side of the semitrailer, crossed underneath it, and then went off the right roadside at a shallow angle. Impact with the underside of the semitrailer sheared off the roof of the car. After leaving the roadway, the car continued through a drainage culvert and two wire fences. It then struck and broke a utility pole, rotated counterclockwise, and came to rest perpendicular to the highway in the front yard of a private residence. Meanwhile, the truck continued across the intersection and came to a stop on NE 140th Court, south of a retail business located on the intersection corner. The driver and sole occupant of the car died in the crash; the commercial truck driver was not injured.
Recommendation: TO THE NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION: Develop a method to verify that manufacturers of vehicles equipped with Level 2 vehicle automation systems incorporate system safeguards that limit the use of automated vehicle control systems to those conditions for which they were designed.
Original recommendation transmittal letter: PDF
Overall Status: Open - Unacceptable Response
Mode: Highway
Location: Williston, FL, United States
Is Reiterated: No
Is Hazmat: No
Accident #: HWY16FH018
Accident Reports: Preliminary Report, ​Highway HWY16FH018Collision Between a Car Operating With Automated Vehicle Control Systems and a Tractor-Semitrailer Truck Near Williston, Florida May 7, 2016
Report #: HAR-17-02
Accident Date: 5/7/2016
Issue Date: 9/28/2017
Date Closed:
Addressee(s) and Addressee Status: NHTSA (Open - Unacceptable Response)

Safety Recommendation History
From: NTSB
Date: 12/20/2018
Response: From the NTSB’s December 20, 2018 ANPRM Comment Letter: The National Transportation Safety Board (NTSB) has reviewed the Department of Transportation (DOT) announcement of an updated policy for Automated Vehicles 3.0 (AV 3.0) and is providing comments. The NTSB has also considered the National Highway Traffic Safety Administration (NHTSA) advance notice of proposed rulemaking (ANPRM), titled “Pilot Program for Collaborative Research on Motor Vehicles With High or Full Driving Automation” (83 Federal Register 196, October 10, 2018). This correspondence includes comments on both AV 3.0 and the ANPRM; we are providing two copies, one for each docket, and request that the correspondence be filed in both dockets. … The DOT’s AV 3.0 policy recognizes operational design domains as an important consideration for operating conditions on roadways. The DOT has stated that it believes that any pilot program for the testing of vehicles with high and full driving automation should include defined operational design domains as a component of safe automated vehicle operation. The NTSB agrees, and also believes that operational design domain constraints should apply to vehicles with all levels of automation, including those classified as Level 2 vehicles. The Williston, Florida, investigation report summarizes the need for operational design domain constraints, addressed in Safety Recommendation H-17-38 (the NTSB’s recommendations from the Williston investigation are listed at the end of this letter). …

From: NTSB
Date: 8/10/2018
Response: We respectfully disagree with your assertion that the guidance in Automated Driving Systems 2.0: A Vision for Safety provides sufficient Level 2 information to assist manufacturers in developing system functions, capabilities, and limitations to avoid safety risks resulting from driver abuse or misuse. We urge you to reconsider your position and develop the recommended verification method for Level 2 systems. Pending such action, Safety Recommendation H-17-38 is classified OPEN--UNACCEPTABLE RESPONSE.

Date: 2/7/2018
Response: -From Heidi R. King, Deputy Administrator: All entities developing automated vehicle technologies are encouraged to adopt voluntary guidance, best practices, design principles, and standards developed by established and accredited organizations such as the International Standards Organization, SAE International, and other applicable standards or internal company processes. While guidance within Automated Driving Systems 2. 0: A Vision for Safety is voluntary, sections pertaining to system safety, operational design domain, human machine interface, validation, and consumer education and training may benefit entities developing ADS. Automated Driving Systems 2. 0: A Vision for Safety, specifically focuses on SAE Levels L3-L5, for which there is either no human driver or for which the human driver can control the ADS, but in certain instances would not be expected to perform any driving-related tasks for a period of time. However, as previously mentioned, parts of the voluntary guidance could be applied to any level of automation. This includes Level 2 - Partial Driving Automation systems, defined by SAE International 13016: Taxonomy and Definitions for Terms Related to On-Road Motor Vehicle ADS, as the driver performing part or all of the dynamic driving task. NHTSA has no current plans to develop a specific method to verify manufacturers of vehicles equipped with Level 2 systems incorporate safeguards limiting the use of automated vehicle control systems to those conditions for which they were designed. Instead, if NHTSA identifies a safety-related defect trend in the design or performance of a system, or identifies through its research or otherwise, any incidents in which a system did not perform as designed (including Levels LO through LS), it would exercise its authority as appropriate. NHTSA continues to be engaged in the development and deployment of lower level systems and is conducting research with these systems in both controlled test track and naturalistic settings. Functions such as traffic jam assist, automated parking, and automated highway driving are being tested to characterize performance and understand the potential safety benefits of the technology. As research is concluded, the agency will make findings available on our website: Collaboratively, NHTSA and all industry stakeholders must work together to ensure we properly educate the motoring public on different levels of driving automation. It is important that drivers understand system functions, capabilities, and limitations to avoid safety risks resulting from abuse or misuse. Based on the information provided, NHTSA plans no further action specific to the recommended action and respectfully requests that NTSB classify Safety Recommendation H-17-38 as "Closed-Acceptable Response."

From: NTSB
Date: 11/13/2017
Response: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration (NHTSA) notice of public availability and request for comments concerning the guidance document “Automated Driving Systems: A Vision for Safety,” published at 82 Federal Register 178, September 15, 2017. As a result of the Williston crash investigation, the NTSB issued multiple safety recommendations addressing the need to incorporate system safeguards to limit the use of automated vehicle control systems to those conditions for which they were designed. The NTSB also recommended that both the US Department of Transportation and NHTSA define the data parameters that must be recorded by vehicles operating with automated control systems of any level. We further recommended the establishment of reporting requirements for automated vehicles addressing incidents, crashes, and vehicle miles traveled with automated systems enabled. Finally, the NTSB recommended that manufacturers of Level 2 automated vehicle systems incorporate safeguards to limit system operations to their intended domains, and develop more effective applications to sense the driver’s degree of engagement with the driving task.

From: NTSB
Date: 9/28/2017
Response: On September 12, 2017, the NTSB adopted its report Collision Between a Car Operating With Automated Vehicle Control Systems and a Tractor-Semitrailer Truck Near Williston, Florida, May 7, 2016, NTSB/HAR-17/02. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at Among the Safety Recommendations are three new recommendations and two reiterated recommendations issued to the National Highway Traffic Safety Administration, which can be found on pages 43 and 44 of the report. The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number.