Insurance Institute for Highway Safety & Highway Loss Data Institute Issues Public Comment on NHTSA Notice

WASHINGTON, Oct. 23 -- David Zuby, executive vice president and chief research officer of the Insurance Institute for Highway Safety and Highway Loss Data Institute, Arlington, Virginia, has issued a public comment on the National Highway Traffic Safety Administration notice entitled "Agency Information Collection Activities; Proposals, Submissions, and Approvals: Event Data Recorders". The comment was written on Oct. 14, 2021, and posted on Oct. 18, 2021:

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The Insurance Institute for Highway Safety and Highway Loss Data Institute (IIHS-HLDI) welcome the opportunity to respond to this request for comments related to motor-vehicle event data recorders (EDRs). We urge the National Highway Traffic Safety Administration (NHTSA) to expand the data collected by EDRs as well as require EDRs for certain vehicles.

IIHS-HLDI support the collection of crash event data as specified in 49 Code of Federal Regulations (CFR) part 563. NHTSA accurately describes in this notice the importance to the agency's work of information captured by EDRs. Similarly, this information supports the broader field of highway safety research, as it provides crash investigators with more accurate information about the circumstances of crashes when the vehicles involved are equipped with EDRs. For example, EDR-enhanced information about front-crash injury risks is informing our efforts to devise new crash tests for our consumer information programs (Brumbelow, 2019), which have been shown to drive vehicle crashworthiness improvements (Zuby, 2015).

As we have commented on earlier occasions (IIHS, 2013, 2018), we urge NHTSA to expand the number and types of elements recorded by EDRs and require that at least certain vehicles be equipped with them, even though the agency estimates that "99.5 percent of model year 2021 light vehicles have a compliant EDR."

New vehicles are increasingly being equipped with crash avoidance and driver assistance features that automate the control of basic vehicle functions--acceleration, braking, and steering. Understanding how these features influence crash risk and outcomes is critical to guiding their development and optimizing their potential. Requiring vehicles with these features to be equipped with EDRs recording an expanded data set would not only serve NHTSA's research and regulatory functions; doing so would also serve foreseeable law enforcement and insurance needs (Karol, 2019). Our prior communications with NHTSA included a proposed list of data elements (also included here, see the Appendix), many of which are further defined in SAE International's Recommended Practice J1698 (2018), which could serve as the basis for amending part 563.

In summary, NHTSA could improve the information collection activities encompassed by 49 CFR part 563 if it amended the regulation to require EDRs to capture data elements related to the use and function of advanced driver assistance features. Capturing this data will help serve the information needs of NHTSA and the highway safety research, law enforcement, and insurance fields.

View appendix at: https://downloads.regulations.gov/NHTSA-2021-0058-0003/attachment_1.pdf

Sincerely,

David Zuby

Executive Vice President &

Chief Research Officer

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References:

Brumbelow, M. L. (2019, September). Front crash injury risks for restrained drivers in good-rated vehicles by age, impact configuration, and EDR-based delta-V. Proceedings of the 2019 International Research Council on the Biomechanics of Injury (IRCOBI) Conference, pp. 561-575.

Insurance Institute for Highway Safety. (2013, February 19). Comment submitted to Docket No. 2012-0177: Proposed establishment of Federal Motor Vehicle Safety Standard No. 405 mandating the installation of EDRs in most light vehicles and meeting the data elements, data capture and format, data retrieval, and data crash survivability requirements.

Insurance Institute for Highway Safety. (2018, April 4). Comment submitted to Docket No. NHTSA-2018-009: Revising the Federal Motor Vehicle Safety Standards to address issues related to automated driving technology.

Karol, T. (2019, December). Responsibility assessment standard for conditional automation/dual control vehicles. National Association of Mutual Insurers. https://www.namic.org/pdf/publicpolicy/200108_cadc_final.pdf

SAE International. (2018, May). Surface vehicle recommended practice J1698-1: Event data recorder--Output data definition. https://doi.org/10.4271/J1698/1_201805

Zuby, D. S. (2015, June). Consumer safety information programs at IIHS. Proceedings of the 24th International Technical Conference on the Enhanced Safety of Vehicles. National Highway Traffic Safety Administration.

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The notice can be viewed at: https://www.regulations.gov/document/NHTSA-2021-0058-0001

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