NHTSA Seeks Input on Electronics Rule

The National Highway Traffic Safety Administration has published a Federal Register Notice seeking comments on the possibility of writing regulations to ensure the safety of automotive electronics. The 10-page request for comments, satisfying a directive from the federal legislation known as MAP–21 to “complete an examination of the need for safety standards with regard to electronic systems in passenger motor vehicles,” would have been an excellent addition to Volume 54 of the Federal Register (published in 1989).

The Pedal Error Error

If the Toyota Unintended Acceleration has taught us anything, it’s the importance of examining NHTSA’s process before accepting its conclusions. The authority of the federal government automatically confers, in large measure, a public (including the mainstream media) acceptance of its pronouncements of scientific certitude. Few take the time to study their foundations. To this end, SRS has devoted more time and resources to obtaining the agency’s original source documents, data and communications around investigations, rulemakings and NHTSA-sponsored reports than we care to count. We have filed numerous Freedom of Information Act requests in pursuit of these informational bases.

Another thing we have learned: NHTSA really doesn’t want the public to know how it does what it does. Our FOIA requests have morphed into FOIA lawsuits (three and counting), as the agency either denies us information that is public or claims to have none, even when the crumbs NHTSA’s FOIA staff toss to us show unequivocally that, in fact, they do have the information.

And that brings us to Pedal Application Errors, NHTSA’s last nail in the Electronically-Caused UA coffin. This report made a number of strong claims regarding who is likely to make a pedal application error and how it is likely to occur. They do not bode well for any woman of a certain age who has the misfortune to be behind the wheel of an electronically caused UA. The report’s writers based on a variety of data sources, including crashes from the Motor Vehicle Crash Causation Survey (MVCCS), the North Carolina state crash database, a media review of pedal misapplication news stories and the insights garnered from a panel of rehabilitation specialists. Naturally, we wanted to look at all these data, and we requested them.

The response from the government, to put it kindly, was less than complete. NHTSA claimed that it didn’t have any of the underlying data, except the list of crashes from the MVCCS. It sent us the transcript of the one-and-a-half day meeting of rehabilitation specialists and Dr. Richard Schmidt, that prodigious peddler of the all-purpose, wholly unsupported and unscientific pedal misapplication theory the auto industry – and NHTSA – loves.

NHTSA Proposes Rubber Stamp Brake Throttle Override Rule

For the second time in 40 years, the National Highway Traffic Safety Administration is attempting to upgrade the accelerator control standard by proposing that manufacturers be required to equip all vehicles with a brake override.  A brake override system cuts throttle voltage in electronic throttle control (ETC) vehicles when the brakes and throttle are in conflict. Variations of this type of fail-safe have been incorporated in a number of ETC equipped vehicles since the 1990s.

“We considered establishing a design requirement as the sole requirement for BTO, but the differences among BTO systems currently available from different vehicle manufacturers are significant enough that a design requirement by itself cannot effectively accommodate them all without being overly complex and/or design restrictive. By combining a relatively simple performance test with the basic equipment requirement described above, we can achieve a robust standard which is largely performance-based and minimally costly or burdensome.”

The Notice of Proposed Rulemaking is in direct reaction to the Toyota Unintended Acceleration (UA) crisis, noting the August 2009 deaths of California Highway Patrol Officer Mark Saylor, his wife, daughter and brother-in-law in Lexus ES350 loaner that experienced a UA event at highway speed. But, the proposal appears to be more of a political response than a technological one. It ignores past recalls for UA events that are electronically caused; and it fails to base this upgrade on any statistical analysis. It merely codifies manufacturers’ current equipment without teasing out the differences between more effective and less effective brake override systems, such as the Toyota system, which doesn’t activate in some of the most frequently reported UA scenarios – when the driver’s foot is on the brake – or on no pedal. According to Toyota’s “Smart Stop Technology,” “the feature doesn’t engage if the brake pedal is depressed before the accelerator pedal. The driver must press the accelerator first and then depress the brake.”

Antony Anderson, a U.K.-based electrical engineering consultant who has studied unintended acceleration, says that the rule fundamentally misses the essential ingredient in any failsafe system – independence from the malfunctioning component. This is why many machines, from motorcycles to escalators, have separate kill switches that can independently remove power from the throttle, he says.

“For some reason, the automobile industry seems to think they don’t need to bother,” Anderson says. [The agency] “has a well-developed NHTSA-speak, where they are all the time trying to minimize the possibility of an electronic malfunction.”

“This just captures the state of the industry, not the state of the art,” says Neil Hanneman, an automotive engineer who have overseen automotive electronic designs and has consulted with Congress on Toyota unintended acceleration. “For it to really be a robust standard it would have to address things that have not been addressed yet – which will be with the electronics.”

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