The U.S. National Transportation Safety Administration has presented new proposed guidelines intended to encourage automakers to mitigate driver distraction when interacting with various in-vehicle applications. The recommendations are not only ambiguous and nearly unenforceable, they reflect a lack of understanding regarding in-vehicle systems in spite of volumes of available research.
The ominously described “first phase” of the guidelines include the following recommendations (as described in a report in Automotive Fleet Top News):
- Reduce the complexity of in-vehicle devices, and the amount of time required to use those devices;
- Limit system operations to require only one hand;
- Limit the time required to glance at a device to no more than 2 seconds;
- Limit the amount of unnecessary visual information in the driver’s field of view;
- Limit the number of manual inputs needed to operate a device;
- Disable functions while the vehicle is in motion – ie. text messaging, Internet browsing, social media use, entering navigation system addresses, entering phone numbers for dialing, displaying more than 30 characters of text unrelated to driving task.
Among the more naïve (if not absurd) statements reported from the DOT was the statement that systems that help drivers avoid accidents (forward collision avoidance systems or lane-departure alerts) were not considered to be distracting and that GPS enabled navigation systems were safer to use than maps. Agency representatives said future guidelines would address devices brought into vehicles and voice-based controls.
NHTSA representatives said they chose guidelines over mandates out of a preference for voluntary compliance from auto makers instead of the coercive power of mandates, according ot the Automotive Fleet Top News report. NHTSA executives reportedly indicated they intend to testify at upcoming NTSB hearings regarding banning the use of all mobile devices in cars and that the agency is awaiting the results of research on cognitive distraction before proceeding with creating additional guidelines.
NHTSA Director Ray Lahood said the new guidelines are now open to a public comment period of 60 days, inviting feedback from the public, automakers, and other interest groups.
The first wave of guidelines listed above read like automotive user interface best practices created by an engineer with no prior experience. Of course designers should reduce complexity; limit interaction to one hand at a time; limit glance time, limit unnecessary visual information; limit manual inputs and disable functions while the vehicle is in motion. But each of the prescriptions is either too specific or two vague.
#1 – Limit complexity and the amount of time required to interface – Is this NOT a no-brainer?
#2 – Limit operation to one hand – Is it necessary to make this a guideline?
#3 – Limit the time required to glance at a device to no more than two seconds – Who is going to measure this and how?
#4 – Limit the amount of unnecessary information in the driver’s field of view – Define unnecessary.
#5 – Limit the number of manual inputs needed – Is there any engineer, anywhere in the industry, trying to ADD unnecessary manual inputs?
#6 – Disable functions while the vehicle is in motion including phone # entry – Best of intentions taken too far.
The Alliance of Automobile Manufacturer’s (AAM) Driver Focus – Telematics Guidelines (http://bit.ly/wmqoX7) represent the gold standard for existing industry design criteria for mitigating distracted driving. Their very existence obviates the need for redundant guideline creation or mandate setting.
The AAM testified before the U.S. House of Representatives in October 2009: “The Guidelines are a ‘best practices’ document that addresses essential safety aspects of driver interaction with visual‐manual interfaces. They consist of 24 principles that address the design, use, and installation of telematics systems with the goal of maximizing ‘eyes on road.’ The Guidelines provide criteria and verification procedures for use by automotive manufacturers and telematic device manufacturers during product development. Each individual Guideline has associated with it:
Criterion / Criteria
Examples (as appropriate)
Cites to supporting peer‐reviewed research
“The 24 guidelines are divided into five groups:
Installation (5 Principles)
Information Presentation (4 Principles)
Interactions with Displays and Controls (6 Principles)
System Behavior (3 Principles)
System User Information (6 Principles)
“The Guidelines assume manufacturers will follow rigorous process standards when developing telematics systems. Let me highlight two key principles:
Principle 1.4 – Addresses the positioning of visual in‐vehicle telematics displays - The proper positioning of displays close to the driver’s normal line of sight allows drivers to continue to monitor the roadway peripherally while looking at the display.
Principle 2.1 – Sets visual demand limits - Eyes‐off‐road time is limited because functions or features must not exceed specified visual demand or driving performance criteria.
It is clear that there is no need for additional guidelines or mandates from NHTSA – or at least not guidelines and/or mandates that do not take into account the progress that has already been made in the industry. Also unnecessary, are guidelines or mandates that do not provide or leave room for advances in user interface technology intended to mitigate distraction and enhance safe driving circumstances.
Some of the emerging solutions take advantage of contextual information including vehicle location, condition of the driver and road and, ultimately, weather conditions and the state of operation of in-vehicle systems. Providing ambiguous “guidelines” without the context of recent and anticipated technological advances risks freezing development activities and preventing new safety systems from reaching consumers.
This latest NHTSA initiative reinforces the notion that U.S. regulators are still at sea in their attempts to fathom and combat the emerging driver distraction phenomenon. Rather than encouraging advances in technology they are steering the industry away from solutions built around voice and touch interfaces that are already helping to resolve the problem.
Rather than embracing and highlighting technology, NHTSA clearly prefers to draw lines in the sand and wall off certain areas of development. In the context of the automotive industry’s existing guideline development, it appears that NHTSA’s efforts are wasteful, redundant and distracting.
Rather than pursuing the existing side show of additional hearings and research, both the NTSB and NHTSA ought to conduct a careful review of the existing AAM guidelines as well as those of similar organizations around the world, and assess whether any additional guidelines are really called for. In the end, the NTSB and NHTSA efforts look like nothing more than public relations programs unlikely to advance the industry’s technical understanding of the causes or potential solutions of distracted driving. Of greater concern is the potential for these regulatory bodies to interfere in ongoing technology advances and actually throw the industry into reverse.