User:Louis/Advanced Impaired Driving Prevention Technology mandate: Difference between revisions

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The Driver Alcohol Detection System for Safety (DADSS) program is a public-private research partnership between NHTSA & the Automotive Coalition for Traffic Safety (ACTS), an automaker consortium, that has been running since 2008.<ref name="dadss">{{Cite web |title=DADSS Program Overview |publisher=Driver Alcohol Detection System for Safety |url=https://dadss.org/ |access-date=2026-05-27}}</ref> DADSS pursues two sensor approaches: a breath-based sensor mounted in the steering column or dashboard that detects exhaled ethanol without a driver blowing into a tube, & a touch-based sensor in the start button or steering wheel that uses infrared spectroscopy to read blood-alcohol concentration through the skin.<ref name="dadss" /> NHTSA's reports to Congress identify DADSS as the technical pathway that an §24220-compliant standard would draw on.<ref name="nhtsa-rtc-2024" /><ref name="nhtsa-rtc-2023" />
The Driver Alcohol Detection System for Safety (DADSS) program is a public-private research partnership between NHTSA & the Automotive Coalition for Traffic Safety (ACTS), an automaker consortium, that has been running since 2008.<ref name="dadss">{{Cite web |title=DADSS Program Overview |publisher=Driver Alcohol Detection System for Safety |url=https://dadss.org/ |access-date=2026-05-27}}</ref> DADSS pursues two sensor approaches: a breath-based sensor mounted in the steering column or dashboard that detects exhaled ethanol without a driver blowing into a tube, & a touch-based sensor in the start button or steering wheel that uses infrared spectroscopy to read blood-alcohol concentration through the skin.<ref name="dadss" /> NHTSA's reports to Congress identify DADSS as the technical pathway that an §24220-compliant standard would draw on.<ref name="nhtsa-rtc-2024" /><ref name="nhtsa-rtc-2023" />


== Consumer & privacy response ==
==Consumer and privacy response==
The strongest privacy submission in the docket is the joint March 5, 2024 comment from the ACLU, EFF, and EPIC. The three organizations argued that the only architectures capable of satisfying the statute's ''"passive"'' requirement on the statute's timeline rely on driver-facing cameras and continuous biometric capture, and that the resulting always-on data flow has no statutory cap on retention or third-party access.<ref name="aclu-eff-epic" />


The strongest privacy submission in the docket is the joint March 5, 2024 comment from the ACLU, EFF, & EPIC. The three organizations argued that the only architectures capable of satisfying the statute's ''"passive"'' requirement on the statute's timeline rely on driver-facing cameras & continuous biometric capture, & that the resulting always-on data flow has no statutory cap on retention or third-party access.<ref name="aclu-eff-epic" />
Consumer Reports filed a separate comment the same day. The organization focused on the false-positive risk implied by the agency's own accuracy numbers, warning that a passive system would have to distinguish impairment from fatigue, medication, and ordinary variations in driver behavior, and that errors at scale would lock sober drivers out of their own vehicles.<ref name="cr-comment">{{Cite web |title=CR Comments to NHTSA on Advanced Impaired Driving Prevention Technology ANPRM |publisher=Consumer Reports |date=March 5, 2024 |url=https://advocacy.consumerreports.org/wp-content/uploads/2024/03/CR-comments-to-NHTSA-on-advanced-impaired-driving-prevention-technology-ANPRM-3-5-2024.pdf |access-date=2026-05-27}}</ref>


[[Consumer Reports]] filed a separate comment the same day. The organization focused on the false-positive risk implied by the agency's own accuracy numbers, warning that a passive system would have to distinguish impairment from fatigue, medication, & ordinary variations in driver behavior, & that errors at scale would lock sober drivers out of their own vehicles.<ref name="cr-comment">{{Cite web |title=CR Comments to NHTSA on Advanced Impaired Driving Prevention Technology ANPRM |publisher=Consumer Reports |date=March 5, 2024 |url=https://advocacy.consumerreports.org/wp-content/uploads/2024/03/CR-comments-to-NHTSA-on-advanced-impaired-driving-prevention-technology-ANPRM-3-5-2024.pdf |access-date=2026-05-27}}</ref>
MADD published its own ''Advanced Impaired Driving Prevention Technology Fact Sheet'' in December 2023 that draws a sharp line between the §24220 mandate & traditional court-ordered ignition interlocks, and assures readers that ''"no one outside the car will have the ability to operate or disable the vehicle."''<ref name="madd-factsheet" /> The privacy submission filed three months later contests that assurance on architectural grounds: the sensor suite that makes passive detection possible is the same sensor suite that would, in principle, support external operation or disablement.<ref name="aclu-eff-epic" />
 
MADD published its own ''Advanced Impaired Driving Prevention Technology Fact Sheet'' in December 2023 that draws a sharp line between the §24220 mandate & traditional court-ordered ignition interlocks, & assures readers that ''"no one outside the car will have the ability to operate or disable the vehicle."''<ref name="madd-factsheet" /> The privacy submission filed three months later contests that assurance on architectural grounds: the sensor suite that makes passive detection possible is the same sensor suite that would, in principle, support external operation or disablement.<ref name="aclu-eff-epic" />


As of the 2024 Report to Congress, NHTSA had not yet issued a Notice of Proposed Rulemaking that would tee up a final standard, and the agency continued to characterize available detection technology as not ready.<ref name="nhtsa-rtc-2024" /><ref name="roadandtrack" />
As of the 2024 Report to Congress, NHTSA had not yet issued a Notice of Proposed Rulemaking that would tee up a final standard, and the agency continued to characterize available detection technology as not ready.<ref name="nhtsa-rtc-2024" /><ref name="roadandtrack" />