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Newest NHTSA Guidelines are Vague and Challenging

by Derek Viita | Nov 23, 2016

This week, NHTSA in the US released its latest set of driver distraction guidelines, focusing on use of portable and aftermarket devices.  These guidelines provide the usual previously-published benchmarks for measuring appropriate levels of visual distraction, as well as 2 recommendations for device engineers and designers:

  • Implementation of "per se" lockouts for visual/manual assets which NHTSA deems too distracting to drivers, including manual text entry for messaging, video unrelated to a driving task, and "certain graphical or photographic images."
  • Integration of a "Driver Mode" for mobile devices, which presents a driver-friendly visual interface with limited features.

From an automotive and mobility UX perspective, these guidelines come at an interesting time.  Consumers are becoming dissatisfied with in-car touchscreens, and mobile device use in the car is on the rise, particularly for navigation-related tasks.

Many items in this latest release are simply carried over from the Phase 1 guidelines for in-vehicle systems, with a doubling-down on the use of lockouts, and no new guidance on a few unclear items.  For example, the definition of “graphical images” is still left largely unresolved.

Furthermore, NHTSA took so long to release these guidelines, the establishment of “Driver Mode” has already been addressed for certain devices.  Apple and Alphabet have already attempted to create their own "Driver Mode" through CarPlay and Android Auto respectively.  In our benchmark studies of both CarPlay and especially Android Auto, we found that consumers prefer the navigation experience of the mobile device over the integrated experience.

NHTSA's recommendation for increased lockouts presents the bigger challenge for device makers and automakers alike.  In this release, NHTSA calls for further research on the ability to distinguish between driver and passenger use.  At the moment this is remarkably difficult to do, and remarkably easy to work around.

As an example:  Waze uses input from the mobile device to detect movement which resembles a vehicle in motion.  When a user attempts to input a destination while such motion is detected, the next screen indicates that the function is locked...... unless the user is a passenger.  But a button is provided at this point to indicate that the user is a passenger, and all any user needs to do is select this button to bring up the screen for manual destination entry (which can be an extremely distracting task by any measure).

These guidelines also fail to present an adequate amount of detail with respect to what constitutes a distracting interface.  For example, the music interface of Android Auto includes album artwork in the background.  Does album artwork presented in this way count as a "photographic or graphical image," and thus constitute a distracting interface?  And if it does, what is to prevent a user from working around the lock-out by simply un-pairing their device and using it as a fully mobile device in passenger mode?

We also find a bit of double-talk in this set of guidelines with respect to lockouts.  Manual text entry for messaging and other communication are marked for lockout, but digit-dialling is specifically cited as being excluded from this requirement.  And to make matters even more confusing, portable navigation devices without pairing capability are also specifically excluded.

Although these guidelines are vague, voluntary, and non-binding, they do provide a window into how the federal government currently views mobile device UI in the car, including the potential for harsher guidelines in the future.  At the moment, this view relies on overly restrictive and ultimately ineffective measures such as lockouts to mitigate what it perceives as distracting visual/manual interfaces.  It is imperative that automotive and mobile OEMs get out in front of this, and work with NHTSA to fully understand the challenges in developing interfaces for the car that are not distracting, but also useful.

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