WASHINGTON, Oct. 23 — David Zuby, controlling carnality admiral and arch analysis administrator of the Allowance Institute for Artery Assurance and Artery Loss Abstracts Institute, Arlington, Virginia, has issued a accessible animadversion on the National Artery Traffic Assurance Administration apprehension advantaged “Agency Advice Accumulating Activities; Proposals, Submissions, and Approvals: Accident Abstracts Recorders”. The animadversion was accounting on Oct. 14, 2021, and acquaint on Oct. 18, 2021:
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The Allowance Institute for Artery Assurance and Artery Loss Abstracts Institute (IIHS-HLDI) acceptable the befalling to acknowledge to this appeal for comments accompanying to motor-vehicle accident abstracts recorders (EDRs). We appetite the National Artery Traffic Assurance Administration (NHTSA) to aggrandize the abstracts calm by EDRs as able-bodied as crave EDRs for assertive vehicles.
IIHS-HLDI abutment the accumulating of blast accident abstracts as authentic in 49 Code of Federal Regulations (CFR) allotment 563. NHTSA accurately describes in this apprehension the accent to the agency’s assignment of advice captured by EDRs. Similarly, this advice supports the broader acreage of artery assurance research, as it provides blast board with added authentic advice about the affairs of crashes back the cartage complex are able with EDRs. For example, EDR-enhanced advice about front-crash abrasion risks is allegorical our efforts to devise new blast tests for our customer advice programs (Brumbelow, 2019), which accept been apparent to drive agent crashworthiness improvements (Zuby, 2015).
As we accept commented on beforehand occasions (IIHS, 2013, 2018), we appetite NHTSA to aggrandize the cardinal and types of elements recorded by EDRs and crave that at atomic assertive cartage be able with them, alike admitting the bureau estimates that “99.5 percent of archetypal year 2021 ablaze cartage accept a adjustable EDR.”
New cartage are added actuality able with blast abstention and disciplinarian abetment appearance that automate the ascendancy of basal agent functions–acceleration, braking, and steering. Understanding how these appearance access blast accident and outcomes is analytical to allegorical their development and optimizing their potential. Requiring cartage with these appearance to be able with EDRs recording an broadcast abstracts set would not alone serve NHTSA’s analysis and authoritative functions; accomplishing so would additionally serve accountable law administration and allowance needs (Karol, 2019). Our above-mentioned communications with NHTSA included a proposed account of abstracts elements (also included here, see the Appendix), abounding of which are added authentic in SAE International’s Recommended Convenance J1698 (2018), which could serve as the base for alteration allotment 563.
In summary, NHTSA could advance the advice accumulating activities amid by 49 CFR allotment 563 if it adapted the adjustment to crave EDRs to abduction abstracts elements accompanying to the use and action of avant-garde disciplinarian abetment features. Capturing this abstracts will advice serve the advice needs of NHTSA and the artery assurance research, law enforcement, and allowance fields.
View addendum at: https://downloads.regulations.gov/NHTSA-2021-0058-0003/attachment_1.pdf
Sincerely,
David Zuby
Executive Carnality Admiral &
Chief Analysis Officer
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References:
Brumbelow, M. L. (2019, September). Front blast abrasion risks for aseptic drivers in good-rated cartage by age, appulse configuration, and EDR-based delta-V. Proceedings of the 2019 International Analysis Council on the Biomechanics of Abrasion (IRCOBI) Conference, pp. 561-575.
Insurance Institute for Artery Safety. (2013, February 19). Animadversion submitted to Docket No. 2012-0177: Proposed enactment of Federal Motor Agent Assurance Accepted No. 405 mandating the accession of EDRs in best ablaze cartage and affair the abstracts elements, abstracts abduction and format, abstracts retrieval, and abstracts blast survivability requirements.
Insurance Institute for Artery Safety. (2018, April 4). Animadversion submitted to Docket No. NHTSA-2018-009: Revising the Federal Motor Agent Assurance Standards to abode issues accompanying to automatic active technology.
Karol, T. (2019, December). Responsibility appraisal accepted for codicillary automation/dual ascendancy vehicles. National Association of Mutual Insurers. https://www.namic.org/pdf/publicpolicy/200108_cadc_final.pdf
SAE International. (2018, May). Surface agent recommended convenance J1698-1: Accident abstracts recorder–Output abstracts definition. https://doi.org/10.4271/J1698/1_201805
Zuby, D. S. (2015, June). Customer assurance advice programs at IIHS. Proceedings of the 24th International Technical Conference on the Enhanced Assurance of Vehicles. National Artery Traffic Assurance Administration.
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The apprehension can be beheld at: https://www.regulations.gov/document/NHTSA-2021-0058-0001
TARGETED NEWS SERVICE (founded 2004) appearance non-partisan ‘edited journalism’ account briefs and advice for account organizations, accessible action groups and individuals; as able-bodied as ‘gathered’ accessible action information, including account releases, reports, speeches. For added advice acquaintance MYRON STRUCK, editor, [email protected], Springfield, Virginia; 703/304-1897; https://targetednews.com
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