Determining Absence of Unreasonable Risk: Approval Guidelines for an Automated Driving System Deployment (2505.09880v2)

Abstract: This paper provides an overview of how the determination of absence of unreasonable risk can be operationalized. It complements previous theoretical work published by existing developers of Automated Driving Systems (ADS) on the overall engineering practices and methodologies for readiness determination. Readiness determination is, at its core, a risk assessment process. It is aimed at evaluating the residual risk associated with a new deployment. The paper proposes methodological criteria to ground the readiness review process for an ADS release. While informed by Waymo's experience in this domain, the criteria presented are agnostic of any specific ADS technological solution and/or architectural choice, to support broad implementation by others in the industry. The paper continues with a discussion on governance and decision-making toward approval of a new release candidate for the ADS. The implementation of the presented criteria requires the existence of appropriate safety management practices in addition to many other cultural, procedural, and operational considerations. As such, the paper is concluded by a statement of limitations for those wishing to replicate part or all of its content.