A Bad Idea From NHTSA

Earlier this year the National Highway Traffic Safety Administration wrote the latest chapter in our government’s continuing preoccupation with universal safety.  NHTSA has released for public comment “Visual-Manual NHTSA Driver Distraction Guidelines for In-Vehicle Electronic Devices”, Docket No. NHTSA-2010-0053… and this comment period expires soon (04/24/2012).

The social phenomenon of government mandated universal safety has been with us for several decades but it took a turn for the worse after the attacks of 9/11.  It now seems no cost is too high to protect us from everything and everyone.  The government continues to propose ever more rules, regulations, “guidelines”, and prohibitions – unaware or uncaring about the cost in wasted money, in lost jobs, and even in crippled innovation and trampled dignity.

To be clear, with this document the government is initiating the process of protecting you from distracted drivers.  To put this in perspective, this is the same government that, for your safety and wellbeing, is mandating your participation in universal healthcare – the constitutionality of which is now being considered by the Supreme Court.  This is also the same government that, with good intentions, accidently created through unforeseen consequences a multi-billion dollar, violent, market in illegal drugs – and a supporting cast of enforcement, incarceration, and interdiction expenses.

I believe the guidelines proposed in this NHTSA document are a well-intentioned desire to improve safety and not some back-door partnership to help car manufacturers continue to charge $2000 for in-dash GPS units.  Indeed, the document itself states:

“NHTSA has opted to pursue nonbinding, voluntary guidelines rather than a mandatory Federal Motor Vehicle Safety Standard (FMVSS) for three principal reasons.”

Unfortunately, however, as an engineer for more than three decades I can assure the NHTSA that they’re good intentions are misguided on this issue.  Although these are “guidelines” and not requirements, my experience, based on hundreds of projects at dozens of companies, says that most of the staff working on automotive designs will abandon innovation and common sense to simply follow the “guidelines”.  Why?  First, it is easier and FASTER to not think and simply copy something already in existence.  Engineering parlance would refer to the guidelines as a “reference implementation”, or in other words, a SAMPLE that is known to work.  Additionally, in the interests of expediency and a more predictable result, corporate management will demand the guidelines be followed.

There is also a darker reason restrictive guidelines will become the de facto standard design and that reason is to remove generic and crossover competitors from the automotive marketplace.  Sales, for example, of GPS and other in car technology have plummeted in the face of smartphone competition.  Car manufacturers and assorted hangers-on, desperate for relief from these unwanted intruders into their profit margin, have already jumped in to support the guidelines with proprietary technology.  I’m not going to mention any of these companies because that will only give them unjustified publicity but one of the web sites says:

“STOP TEXTING WHILE DRIVING”, ‘x’ is the world’s leading technology to stop distracted driving.”

Don’t get me wrong – distracted driving is bad.  Here are the statistics provided in the NHTSA document concerning police-reported crashes involving a distracted driver:

2006 17%
2007 17%
2008 17%
2009 17%
2010 17%

I’m not sure I see the urgent problem here, specifically, Apple introduced the iPhone in 2007 and Android followed in 2008.  So, in 2006 any distracted driving problem from smartphones must have been BlackBerry, Palm, and such.  While smartphones sales in the United States soared by tens of millions the police reported distracted driving number stayed around 17%.  It would be great if we could lower this number but perhaps the best way to do so is through continuing education and the punishment of those who refuse to learn.  Perhaps the worst approach is to stomp in with government defined technology – which may well be the next step in our “protection”.

For over 60 years people have been playing with their car radio while driving and a few years ago a friend of mine ran off the road while trying to shoo a bee out of the car.  Distracted driving is not a new problem – although activities enabled by new technology may require a learning period.

I envision a world where the government is an ENABLER, not a disabler or “prohibiter”.  That is, the government, within reason, should never REQUIRE you to do something, nor FORBID you from doing something.  They should educate, advise, and mentor – then get out of the way.

The government process and government regulations, recommendation, and guidelines can never keep up with the rapid advancement of technology.  They must stay out of the way and not condemn us to an automotive world lacking innovation, vision, and above all not lacking in competition from alternative technologies and companies.

If you want to read the actual NHTSA proposal you can find a double spaced PDF.

An (as far as I can tell) identical version with better PDF formatting here.

It is also available as HTML.

The comment period ends 04/24/2012, so hurry and make your comments.

Search for ” NHTSA-2010-0053″.