A robust safety assurance system along with legislation and laws to support the use and ongoing compliance of automated vehicles, Automated Driving System Entities (ADSEs) and their users is essential.

In its submission to the NTC the ATA raises concerns that the NTC has not considered Work Health and Safety (WHS) legislation and how this may apply to the safety assurance and ongoing compliance of automated vehicles. The ATA advocates that any new laws made to specifically address the liability of an ADSE must be consistent with the existing WHS laws and that the planned Road Vehicle Safety Act (Cwth) should be amended to impose a primary safety duty on ADSEs.

Traffic violations and speeding tickets issued to automated vehicles should be seen and investigated as evidence that the vehicle technology needs improvement. Road transport businesses should not be held responsible for traffic infringements that are caused unavoidably by an automated driving system (ADS).

The ATA urges that removing drink and drug driving offences could have far reaching social implications and should not just be viewed as related to the dynamic driving task. Impairment by alcohol or drugs may threaten the safe operation of an ADS and all road users.