FMVSS Considerations for Vehicles 

with Automated Driving Systems

Myra Blanco, Michelle Chaka, Clay Gabler, Loren Stowe, 

Warren Hardy, Joshua McNeil, and Vikki Fitchett

Virginia Tech Transportation Institute

Ellen Lee

National Highway Traffic Safety Administration
Project Objectives

■ Identify unnecessary/unintended regulatory barriers to 

self-certification and compliance verification of 

innovative vehicle designs with Automated Driving 

Systems (ADS)

■ Provide technical translation options of FMVSS and 

related compliance test procedures for ADS-equipped 

vehicles

■ Focus is on ADS-Dedicated Vehicles (ADS-DVs) that 

lack manually operated driving controls (e.g., steering 

wheel, brake pedal)

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FMVSS of Focus

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Translation Approach 

■ Detailed evaluation of both regulatory text and the compliance test 

procedure to identify unnecessary barriers 

■ Code the translation

type as 0, 1, or 2

■ Suggest potential 

translations of 

standard text and

test procedures

■ Document FMVSS requirements where a technical translation was 

evaluated but not performed 

■ Document potential considerations for translation options

■ Engage subject matter experts for review 

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Project Team and Stakeholders
Translation Approach: Maintaining 

Consistency

■ Driver (operator)

■ Equipment may not be available

■ Front/rear of vehicle

■ Assumes front row is preferred 

seating

■ Dummy positioning

■ Controls, Telltales, Indicators 

and Alerts

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■ Driver

■ Driver’s Designated Seating 

Position (DSP)

■ Manually Operated Driving 

Controls

■ Bidirectional Vehicle

Cross-Cutting Themes Working Definitions
6/23/2019 insert footer

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S3.1.4.2 Identification of shift positions and of shift position sequence

Regulatory Text Translation Options Potential Considerations

...identification of 

shift positions ... 

shall be 

displayed in view 

of the driver

whenever the 

ignition is in a 

position in which 

the engine is 

capable of 

operation.

Option 

1 ...shall be communicated to the driver ...

Eliminates the dependency on a 

display.

Opens the possibility of other 

communication means to human 

drivers (e.g., auditory). 

Option 

2

...shall be displayed in view of the driver in a 

vehicle with a transmission shift mechanism 

intended for operation by a human driver, and 

shall be communicated to the ADS driver in a 

vehicle equipped with such a system, 

whenever...

Separates the human and ADS.

If taken out of context, exclusion of 

"shift" could be ambiguous. "Shift" 

could be kept as currently stated 

while keeping the distinction 

between human and ADS.

Option 

3

...shall be displayed in view of the human driver 

whenever the ignition is in a position in which 

the engine is capable of operation.

Only display information for vehicle 

operated by a human driver.

Technical Translation Example: 

FMVSS 102: Transmission Shift Position Sequence
Test Procedures: Crash Avoidance

■ Goal was to investigate the equipment, methods, and/or procedures to 

perform compliance testing on ADS-DVs

■ Evaluate functionalities required to execute compliance test procedures 

using as many potential test methods as are technically feasible

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Test Procedures: Methods

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Simulation

Technical design 

documentation

ADS normal operation

Programmed control of 

the ADS

Human control

Test Methods
Test Procedures: Evaluation Criteria

■ Safety

■ Ease of execution 

(compared to baseline)

■ Test time

■ Scalability 

■ Standardization

■ Cost

■ Gaming Possibility

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Test Procedures: Crashworthiness

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■ Conventional Seating

■ Occupant protection 

from right passenger 

mirrored to left 

passenger if no manual 

controls present

■ Focus on seating 

position (Driver’s DSP, 

Passenger DSP) rather 

than role (Driver, 

passenger)
Conclusions

■ Unnecessary regulatory barriers identified for 30 FMVSS

■ Technical translation options developed to maintain safety 

and performance standards of each FMVSS

■ Multiple test methods established for testing the different 

functionalities required to execute compliance test 

procedures for ADS-DVs

■ Stakeholder and subject matter expert feedback captured 

throughout process

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Thank you!

Ellen Lee, NHTSA

ellen.lee@dot.gov

Myra Blanco, VTTI

mblanco@vtti.vt.edu