FMVSS Considerations for Vehicles with Automated Driving Systems: Volume 1

Blanco, Myra; Chaka, Michelle; Stowe, L.; Gabler, H. Clay; Weinstein, Kenneth; Gibbons, Ronald B; Neurauter, Luke; McNeil, Joshua; Fitzgerald, Kaitlyn E; Tatem, Whitney; Fitchett, Vikki · 2020 · ROSA P / United States. Department of Transportation. National Highway Traffic Safety Administration

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Summary

This report, produced by the Virginia Tech Transportation Institute for the National Highway Traffic Safety Administration (NHTSA), addresses regulatory barriers preventing the compliance verification of Automated Driving System-dedicated Vehicles (ADS-DVs). ADS-DVs are defined as vehicles designed exclusively for SAE Level 4 or 5 automation, lacking manually operated driving controls such as steering wheels or pedals. The study aims to identify "technical translations"—modifications to Federal Motor Vehicle Safety Standards (FMVSS) regulatory text and test procedures—that allow these innovative designs to meet safety performance requirements without relying on manual control-specific restrictions. The research focused on 12 specific FMVSS: six crash avoidance standards (Nos. 102, 108, 114, 118, 138, and 141) and six crashworthiness standards (Nos. 201, 202a, 203, 204, 205, and 206). The methodology involved analyzing regulatory language and Office of Vehicle Safety Compliance (OVSC) test procedures to identify unintended barriers. For crash avoidance standards, the team developed test method options categorized as either vehicle-based (using physical vehicles modified with actuators to simulate ADS functionality) or non-vehicle-based (using technical documentation or simulation). For crashworthiness standards, the analysis focused on occupant protection in ADS-DVs with conventional seating, proposing that test procedures for passenger seating positions be applied to the left front outboard position in the absence of manual controls. The process included stakeholder and subject matter expert reviews to validate feasibility. Key findings include the identification of specific regulatory barriers, such as references to steering columns, driver seats, or rearview mirrors, which are absent in ADS-DVs. The report provides detailed technical translation options for each of the 12 standards, including alternative definitions for terms like "driver" and "seating position," and modified test procedures for features like transmission shift sequences, theft protection, and tire pressure monitoring. For crashworthiness, the report suggests adapting existing passenger seat protocols for driver-side positions in vehicles without steering controls. The study also analyzed standards incorporated by reference from organizations like ANSI, ASTM, and ISO to ensure comprehensive coverage. The significance of this work lies in providing a structured framework for NHTSA to update FMVSS to accommodate automated vehicles. By offering specific technical translation options, the report facilitates the certification of ADS-DVs while maintaining engineering performance standards. However, the authors note limitations: the legal validity of the proposed options has not been verified, the options are not exhaustive, and stakeholder input was predominantly from industry representatives rather than public interest groups. This report serves as a foundational step for future rulemaking to ensure safety standards remain relevant for next-generation vehicle designs.

Key finding

Technical translation options were developed for twelve FMVSS to allow compliance verification for ADS-dedicated vehicles lacking manual controls, though the legality of these options was not verified.

Methodology

review

Provenance

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Summary generated by qwen3.6-27b-prismaquant on 2026-06-10; verification: verified.

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• dms regulation
• driverless ads
• odd communication
• ehmi external hmi

Information type

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• Applied Guidance: standards test procedures, design guidelines
• Theoretical Contribution: conceptual framework