Obtain ALKS type approval within the declared operating conditions and implement safety and failsafe requirements
Severity Criticalparas 1.1, 2.1, 2.1.1, 2.7；Introduction
Apply for ALKS type approval for M1 vehicles under this Regulation, defining the vehicle type with regard to ALKS (vehicle features significantly influencing ALKS performance, and the system characteristics and design of the ALKS). Once activated the system must perform the driving task instead of the driver, manage all situations including failures without endangering occupants or other road users, and remain overridable by the driver at any time. A safe handover of the driving task must be implemented, with a minimum risk manoeuvre bringing the vehicle to a stop where the driver does not respond appropriately.
- Applies when
- Vehicle manufacturers seeking ALKS type approval and the Tier 1 suppliers providing the automated driving system.
- Evidence to retain
- · Vehicle type definition for ALKS covering performance-relevant vehicle features and system design
- · Boundary definition of operating conditions (road type, speed, weather, traffic scenarios) and the exit strategy when boundaries are exceeded
- · Failsafe response design and fault injection test reports
- · Design and test records for the transition demand and the minimum risk manoeuvre
- · Human-machine interface design description, with evidence that non-driving-activity displays are suspended on a transition demand
Estimated first-time effort: 60–180 person-days (estimate, not a commitment)
Fit a Data Storage System for Automated Driving (DSSAD) meeting the paragraph 8 requirements
Severity Highparas 2.15, 2.17, 8.1；Annex 4
Every ALKS-equipped vehicle must be fitted with a DSSAD enabling the determination of interactions between the ALKS and the human driver. The DSSAD must record the defined occurrences, that is actions or instances of arising events or incidents that require storage in the data storage system. The manufacturer must demonstrate fulfilment of paragraph 8 to the technical service during the inspection of the safety approach as part of the Annex 4 assessment, and an operational DSSAD is one of the conditions for the system to be activated.
- Applies when
- Vehicle manufacturers and their data platform teams; in export markets DSSAD data usually also engages local personal data protection and accident investigation evidence rules, which must be designed for in parallel.
- Evidence to retain
- · DSSAD design specification and mapping of the defined occurrences
- · Test reports on DSSAD record integrity, tamper resistance and retrieval method
- · Verification record that an operational DSSAD is a condition for system activation
- · DSSAD retention period, access authorisation and authority-disclosure procedure
Estimated first-time effort: 15–45 person-days (estimate, not a commitment)
Pass the Annex 4 safety management system process audit and cascade requirements to suppliers
Severity CriticalAnnex 4 §3.5.1, §3.5.2, §3.5.6
For the software and hardware employed in the system, the manufacturer must demonstrate to the type approval authority, in terms of a safety management system, that effective processes, methodologies and tools are in place, up to date and actually followed within the organisation to manage safety and continued compliance throughout the product lifecycle (design, development, production, operation, decommissioning). The design and development process must cover the safety management system, requirements management, requirements implementation, testing, failure tracking, remedy and release. The manufacturer must also put suitable arrangements in place with suppliers — contractual arrangements, clear interfaces, quality management systems — so that supplier safety management systems comply with the corresponding requirements.
- Applies when
- Vehicle manufacturers; Chinese automated-driving software and hardware suppliers are audited item by item against supplier safety management system conformity.
- Evidence to retain
- · Safety management system manual and lifecycle process map (design, development, production, operation, decommissioning)
- · Process records and traceability matrix for requirements management, implementation, testing, failure tracking and release
- · Process audit report and non-conformity closure records
- · Safety interface agreements with suppliers, quality management system evidence and audit records
Estimated first-time effort: 40–120 person-days (estimate, not a commitment)
Operate a closed-loop field monitoring process and report critical incidents to the type approval authority
Severity HighAnnex 4 §3.5.4
The manufacturer must have processes to monitor safety-relevant incidents, crashes and collisions caused by the engaged automated lane keeping system, a process to manage potential safety-relevant gaps after registration (a closed loop of field monitoring) and to update the vehicles, and must report critical incidents — for example collisions with other road users and potential safety-relevant gaps — to the type approval authority. This requires wiring overseas fleet incident data collection, analysis and remediation into the OTA release process.
- Applies when
- Vehicle manufacturers and their overseas aftersales and data teams; processing the returned data in China also engages Chinese data export and automotive data rules.
- Evidence to retain
- · Field safety incident monitoring process and severity criteria defining a critical incident
- · Incident ledger and root-cause analysis reports
- · Records and acknowledgements of critical incident reports sent to the type approval authority
- · Closed-loop records linking safety gap remediation to OTA releases
Estimated first-time effort: 20–60 person-days (estimate, not a commitment)