Automakers asked NHTSA to publish its drowsiness test protocol before the study runs

The Alliance for Automotive Innovation filed a comment with the National Highway Traffic Safety Administration on October 26, the closing day of the comment period, on the agency’s proposed information collection for a study of driver drowsiness detection.

NHTSA’s August 26 notice described a one-time voluntary collection from 48 licensed drivers, split between a test track in the Phoenix area and a driving simulator in Iowa City, with a total burden of 320.5 hours. Track participants would drive at 11 p.m., 1:30 a.m. and 4 a.m. after at least 16 hours awake, recorded by a video camera, an infrared camera and a driver monitoring system. The notice said the collection will not develop an objective test procedure for use in a Federal Motor Vehicle Safety Standard.

The Alliance said it generally supports the research, but that it was unclear whether the final report may function as de facto agency guidance without an opportunity for public notice and comment, or whether it is intended to feed an update to the New Car Assessment Program. It disputed the agency’s statement that no consensus approach exists for testing drowsiness detection, citing Euro NCAP protocols and Annex I, Part 2 of Commission Delegated Regulation (EU) 2021/1341, which it said manufacturers use to inform driver monitoring design.

The association asked NHTSA to publish the draft test procedure it plans to evaluate, to keep any recommendations performance-based and technology-neutral, and to say whether the protocols would distinguish standalone drowsiness detection from integrated systems that also address inattention, speeding, impairment and incapacitation. It also raised consumers disabling nuisance warnings.

CorrActions filed a separate comment the same day, arguing that electroencephalography should be the mandatory ground truth against which any driver monitoring system is tested.