Traffic safety

Moving ahead with automated driving

Automated and autonomous driving systems have the potential to fundamentally change mobility. They can not only help improve traffic safety, ride comfort, and driving behavior on long trips; they could also have a positive influence on personal mobility and the transport of goods. At the same time, we need to keep in mind the potential risks associated with such systems.

Opportunities and challenges

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Automated driving systems that require no human operation or relieve drivers of certain responsibilities can help reduce the number of traffic accidents. That’s because such systems would never become tired or distracted or allow themselves to be influenced by emotions or moods, all of which are factors that frequently play a role in accidents today.

The potential improvement of traffic safety is not the only benefit offered by automated driving systems. The technology can also enable efficient, resource-saving traffic in both urban and rural areas, which contributes to reducing emissions. It also offers us new opportunities and the possibility of establishing new business models. Such models could include digital and service-based innovations and various environmentally friendly mobility services, including special urban offers that could benefit the elderly or people with disabilities. Automated driving systems also offer extensive potential for road freight transport in terms of safety and the economic benefits brought about by, among other things, efficiency enhancements and fuel savings. We are currently testing highly automated driving systems (SAE Level 4) on selected public roads in the United States.

The use of artificial intelligence (AI) poses a further challenge. AI will play a particularly important role in machine learning systems that will be used in automated and autonomous vehicles. For example, AI can help automated systems detect and identify objects in or next to the roadway more quickly.

Along with safety, we believe that the responsible use of AI and the consideration of ethical aspects are key preconditions for society’s acceptance of automated and autonomous driving. Since 2018, a cross-functional team at Daimler has been developing internal principles for the responsible use of AI. These principles were presented at the IAA 2019. The AI principles are based on our corporate values and have also been incorporated into our Integrity Code.

At the same time, hardware – i.e. the vehicle itself – needs to meet certain social standards related to the design of vehicle interiors and barrier-free access for all future customers.

On the road to automated driving

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New technologies require legal certainty. In Germany, the legal basis for automated driving systems is defined by the automated driving amendment to the Road Traffic Act (StVG), which went into effect on June 21, 2017. We welcome this amendment because it makes Germany one of the first countries to provide a legal basis for further technological developments. Beyond that, we also believe that respective national traffic and regulatory laws need to be further developed in order to establish legal certainty in connection with the use of autonomous and automated systems. Further changes need to be made to traffic laws in particular if fully automated driving is to become a reality.

Many other countries have now created legal frameworks or initiated legislative processes. If the technology is to achieve a breakthrough, not only will amendments have to be made to respective national regulatory laws; measures will also have to be taken to make it possible to approve and register conditionally and highly automated driving systems (SAE Levels 3–4) for actual use on the road. Daimler is therefore participating worldwide in international committees and associations that are addressing the relevant issues. In this manner, we seek to support the development of a secure legal framework for the technical certification of these systems.

Daimler also supports the international harmonization of regulations regarding automated and autonomous driving in order to ensure that such regulations are compatible with one another to the greatest extent possible and that technological requirements will be uniform all over the world. This also relates to the collection and use of the data needed to ensure the proper operation of automated driving systems. An example is the technical standardization of the driving mode recorder that is required by law in Germany. Among other things, this device records whether an automated system was activated or the driver controlled the vehicle. Experts from the United Nations Economic Commission for Europe (UN-ECE) are currently exploring ways to establish an international technical standard for such a recorder. We support this effort and emphasize the importance and necessity of ensuring data security in such recording technologies.

Our approach toward the responsible development of automated vehicles is based on legal and internal provisions and policies such as our Internal Guideline on Technical Compliance, ISO standards 26262 and 21448 for safety-relevant electrical/electronic systems in vehicles, the UN-ECE proposals for Requirements for an Automated Lane Keeping System, and the German government Ethics Commission’s 20 ethical rules on automated and connected driving.

Our four AI principles also play an important role here. Our first principle requires us to design AI systems responsibly. We use the opportunities offered by AI but also assess its effects as they might relate to our corporate values. Our second principle requires us to ensure a high level of transparency in order to promote trust in AI systems. To this end, we support explainable AI. Our third principle stipulates respect for our customers’ privacy. We take privacy protection into account as early as the AI design phase and we support privacy-enhancing technologies. Finally, we develop and test our AI technologies conscientiously using state-of-the-art scientific and technological systems, and we take adequate measures to develop safe and reliable AI systems.

The AI principles are designed to promote trust and quality in our products and services as well as strengthen our products and services while also serving as a guide for all employees who work with or on AI systems.

Aside from ethical considerations, effective data protection is important for ensuring acceptance of automated and autonomous driving systems. This is why we involve our data protection experts in our concept-development processes at a very early stage. The goal here is to develop data-protection-friendly concepts in accordance with the “privacy by design” principle.

Covering and mitigating risks

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The elements and processes defined in our technical Compliance Management System (tCMS) are also used in the area of automated driving. Particular challenges arising from the utilization of new technologies such as those for automated driving systems are continually taken into account in our development units through the use of behavior guidelines. Complex questions related to automated driving are examined and answered in an interdisciplinary process that takes legal and technical criteria into account.

Expertise in the responsible use of new technologies

The development and introduction of new technologies not only presents technical challenges but also requires consideration of the social, ethical, and legal questions that need to be discussed and answered in a broad-scale dialog. We use an integrated approach to address all of these challenges and questions. This approach involves not only our activities in the areas of research and development, product safety, and quality management; since 2018 it has also included the work conducted by an interdisciplinary team at the Integrity and Legal Affairs executive division. The team works with engineers, legal advisors, and data protection, compliance, and strategy experts to assess the potential impact of new technical developments, increase awareness of complex social and legal issues, and develop and implement new solutions. The topics addressed include the responsible use of data in programming processes and the identification of possible changes to behavior in urban environments that might be brought about by the use of new technologies. The objective also always involves increasing the public acceptance and the safety of our products. Our activities are guided by legal requirements, internal rules and regulations such as our Integrity Code and data-protection and AI principles, external guidelines such as AI4People and the IEEE and Asilomar guidelines, and the German government Ethics Commission’s 20 ethical rules on automated and connected driving.

Our targets

Our goal is to continue developing the requisite technology and to rapidly enable automated and autonomous systems to be installed in series-produced vehicles. As we pursue this goal, we are placing equal emphasis on technical, legal, and ethical aspects, for which we have defined three focal areas:

  • Daimler seeks to play a leading role in the field of automated and autonomous systems and will continue to forge ahead with the technical developments needed to create and implement such systems.
  • Daimler wants to support the establishment of a reliable legal framework for the use of the relevant new technology at both the national and international levels and therefore promotes the broad-based public dialog needed for this.
  • Daimler will actively participate in the social and political dialog on the ethical questions that are arising in the context of the new technologies.

Measures for automated driving

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Our measures for establishing the use of automated and autonomous systems range from research and development activities aligned with our principles to social discourse on ethical questions and issues.

Discussing technical, legal, and ethical issues

A broad-based social discussion is a prerequisite for the acceptance of automated and autonomous driving systems. That is why it is so important to engage in an open dialog with business and consumer associations, various interest groups, government authorities, industry, and society at large. We promote this dialog by staging events and specialist conferences, for example. Since 2015 we have also been using the annual “Daimler Sustainability Dialogue” to discuss ethical, legal, and social questions in connection with autonomous driving. The most recent Daimler Sustainability Dialogue took place in November 2019 in Stuttgart. Participants at the event talked about the possible changes that all road users and society in general might have to make to their behavior as a result of the introduction of new technologies or business models in urban settings. The participants also drew up scenarios related to such new types of behavior and formulated proposals on how the development of new technologies might be used to benefit society as a whole. The focus was on the responsibility vehicle manufacturers and their suppliers have toward society.

Shaping the legal framework

A basic requirement for the successful further development and introduction of automated, autonomous and connected vehicles is the timely creation of a legal framework. Daimler therefore plans to continue to actively promote the relevant legislative processes. Along with the amendments that have to be made to respective national traffic laws and regulatory provisions, particularly with regard to fully automated driving, there are additional hurdles that need to be overcome if the technology is to achieve a breakthrough. In order to enable the cross-border use of automated and autonomously driving cars in road traffic, international harmonization of the relevant legal regulations is necessary. These should be as compatible as possible and include the same technological requirements.

Involvement in committees and associations

Daimler is a member of numerous national and international committees and associations, including the German Association of the Automotive Industry, the European Automobile Manufacturers’ Association, and the working groups of the UN-ECE. Within the framework of these memberships, we participate in consultation processes regarding new legislation and share ideas and information with political decision-makers.

  • Daimler joined the Automated Vehicle Safety Consortium (AVSC) in April 2019. The consortium develops safety principles for automated driving, with a focus on safety tests before and during the use of automated vehicles, data processing and protection, and the interaction between automated vehicles and other road users.
  • In July 2019 we participated in a workshop on “Ethical aspects of the standardization of artificial intelligence in autonomous machines” that was organized by the German Institute for Standardization (DIN). The workshop was part of our partnership with DIN and the German Commission for Electrical, Electronic & Information Technologies. The goal of this partnership is to create a roadmap to be known as “Ethical aspects of the standardization of AI.”
  • In July 2019, eleven leading companies from the automotive and automotive supplier industries, including Daimler, published a white paper titled “Safety First for Automated Driving.” The white paper defines twelve guiding principles that are meant to serve as a foundation for future discussions.
  • We are also a member of a working group in the German Association of the Automotive Industry that is examining the issue of “Ethical considerations related to autonomous vehicles.”
  • In addition, we participated in a consortium project known as PEGASUS, which was funded by the Federal Ministry for Economic Affairs and Energy. PEGASUS stands for “Project for the establishment of generally accepted quality criteria, tools, and methods as well as scenarios and situations.” The goal of the project was to develop an approach that will lead to the approval of automated driving functions and thus enable the rapid introduction of automated driving systems in road traffic.
  • Since July 2019 we have also been participating in the research association for “Legally Viable and Efficient Homologation of Level 4 and Level 5 Autonomous Vehicles.” This association, which basically picks up where PEGASUS left off, has set itself the goal of developing systems and methods for the safety verification of highly automated and fully automated vehicles and vehicle functions.

Ethical principles in product development

In accordance with the guidelines of the German government Ethics Commission, our AI principles, and various other principles (such as biomedical and ethical principles), we have made ethics an integral element of our technology development activities. That is why we take not only legal but also ethical aspects into consideration when we develop products for automated driving systems. We are convinced that this approach will have a positive impact on the acceptance our future products will enjoy, and thus on our ability to generate sustainable value. We therefore view this approach as an important component of our sustainable business strategy.

Safety in autonomous and automated vehicles

Automated driving systems will need to demonstrate proven safety if automated vehicles are to be approved for road use. We are working hard to define the required technical standards. We have made some important progress here with the “Project for the establishment of generally accepted quality criteria, tools, and methods as well as scenarios and situations” (PEGASUS), which was funded by Germany’s Federal Ministry for Economic Affairs and Energy. Key issues related to test methods and approval procedures for conditionally automated driving functions had been resolved by the time the project was completed in June 2019. We support the continuation of related activities and their harmonization with international efforts in this area.

In the United States we have published Voluntary Safety Self-Assessments (VSSAs) of our joint projects with our partner Bosch in Sunnyvale, California (SAE Levels 4–5), and of DRIVE PILOT (SAE Level 3) in Long Beach, California and Ann Arbor, Michigan. These voluntary disclosures are designed to promote public discussions with government organizations and stakeholders about the projects. Daimler is the first German original equipment manufacturer (OEM) to make use of the VSSA system in the United States.

Automated driving in commercial vehicles

Autonomously driving trucks offer clear benefits in many different respects. For one thing, they can help make road transport safer and more sustainable. Redundant systems and numerous sensors and systems that never get tired or stop paying attention form the basis of automation technologies and assistance systems. This is important, because the majority of accidents that occur today are still caused by human error. Daimler Trucks already offers partially automated driving systems (SAE Level 2) ex works. These systems are available in trucks from our Mercedes-Benz, Freightliner, and FUSO brands in our most important markets on three continents.

In commercial transport, highly automated driving (SAE Level 4) is the logical next step, as this level of automation could significantly further increase safety, efficiency, and productivity. Since the competitiveness of an economy also depends on efficiency in logistics, highly automated driving could have positive effects in this respect. Daimler Trucks focuses on three principles when researching and developing automated trucks:

  • The safety of vehicle occupants and other road users is our top priority. Thus, all technical systems need to be absolutely reliable.
  • We develop our products in cooperation with our customers.
  • A clear legal and regulatory framework for issues related to vehicle operation and liability must be established.

Combining expertise and establishing strong partnerships

Daimler Trucks will focus on the development of highly automated trucks (SAE Level 4) up to the series production stage over the next few years. This is why the Autonomous Technology Group was established as a global organization in 2019. The Autonomous Technology Group brings together our expertise and all of our global activities related to automated driving. The unit’s responsibilities include the formulation and implementation of an overall strategy for automated driving, including all research and development activities, and the establishment of the required infrastructure and network for vehicle operation.

Torc Robotics, a software firm located in Blacksburg, Virginia in the United States, is part of our Autonomous Technology Group. Torc Robotics is one of the world’s most experienced companies in the field of automated driving with highly sophisticated, roadworthy technology. Daimler and Torc have already begun jointly testing highly automated trucks (SAE Level 4) on selected public roads. Previously, we had tested the technology for months on closed-off tracks. These activities mark an important further step that supports Daimler Trucks’ efforts to offer safe and reliable trucks that benefit our customers, the economy, and society as a whole.

How we assess the effectiveness of our management approach

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The elements and processes defined in our technical Compliance Management System (tCMS) are also used in the area of automated driving. Every year we review the adequacy and effectiveness of our tCMS and adapt it to global developments, changed risks, and new legal requirements. In addition, we analyze the knowledge gained through independent internal and external assessments. On this basis, improvement measures that may be necessary are determined

The sound decisions made in our development projects form the foundation for ensuring technical compliance. Certain potentially feasible future developments are still not addressed in the external provisions and regulations regarding automated driving systems. All employees at the development departments can submit technical compliance questions to the responsible tCMS units, which then make their decisions within the framework of an interdisciplinary tCMS Clearing Process. During the reporting year, the established tCMS units used this interdisciplinary process to clear numerous cases related to automated driving.

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Daimler AG Mercedesstraße 120
70372 Stuttgart
Germany
Tel.: +49 711 17 0
E-Mail: dialog@daimler.com

Represented by the Board of Management: Ola Källenius (Chairman), Martin Daum, Renata Jungo Brüngger, Wilfried Porth, Markus Schäfer, Britta Seeger, Hubertus Troska, Harald Wilhelm

Chairman of the Supervisory Board: Manfred Bischoff

Commercial Register Stuttgart, No. HRB 19360
VAT registration number: DE 81 25 26 315