Op-Ed About Autonomous Vehicle Safety

Yesterday the local newspaper published my op-ed piece on the DoT's draft policy for autonomous vehicle safety.  In the interest of starting a more general public discussion about this important topic, it is reproduced below.  I am working a more comprehensive technical response, and I'll post that here soon.

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Source:
http://www.post-gazette.com/opinion/Op-Ed/2016/09/30/Safe-self-driving-It-s-not-here-yet/stories/201609300137

Safe self-driving? It’s not here yet
A lot of testing remains before self-driving cars should be widely deployed
Pittsburgh Post-Gazette
September 30, 2016 12:00 AM

By Philip Koopman and Michael Wagner

President Barack Obama this month announced a Department of Transportation draft policy on automated-vehicle safety. Hard-working staff at the Department of Transportation, the National Highway Traffic Safety Administration and the Volpe National Transportation Systems Center did a great job in creating it.

But, while self-driving cars promise improved safety, some critical issues must be addressed to ensure they are at least as safe as human-driven cars and, hopefully, even safer.

Machine learning is the secret sauce for the recent success of self-driving cars and many other amazing computer capabilities. With machine learning, the computer isn’t programmed by humans to follow a fixed recipe as it was in traditional systems. Rather, the computer in effect teaches itself how to distinguish objects such as a bush from a person about to cross a street by learning from example pictures that label bushes and people.

Traditional software safety evaluations check the software’s recipe against its actual behavior. But with machine learning, there is no recipe — just a huge bunch of examples. So it is difficult to be sure how the car will behave when it sees something that differs even slightly from an example.

To take a simple example, perhaps a car will stop for pedestrians in testing because it has learned that heads are round, but it has trouble with unusual hat shapes. There are so many combinations of potential situations that it is nearly impossible to simply test the car until you are sure it is safe.

Statistically speaking, even 100 million miles of driving is not enough to show that these cars are even as safe as an average human driver. The Department of Transportation should address this fundamental problem head on and require rigorous evidence that machine-learning results are sufficiently safe and robust.

A key element of ensuring safety in machinery, except for cars, is independence between the designers and the folks who ensure safety. In airplanes, trains, medical devices and even UL-listed appliances, ensuring safety requires an independent examination of software design. This helps keep things safe even when management feels pressure to ship a product before it’s really ready.

There are private-sector companies that do independent safety certification for many different products, including cars. However, it seems that most car companies don’t use these services. Rather than simply trust car companies to do the right thing, the Department of Transportation should follow the lead of other industries and require independent safety assessments.

Wirelessly transmitted software updates can keep car software current. But will your car still be safe after a software patch? You’ve probably experienced yourself cell phone or personal computer updates that introduce new problems.

The Department of Transportation’s proposed policy requires a safety re-assessment only when a “significant” change is made to a vehicle’s software. What if a car company numbers a major new software update 8.6.1 instead of 9.0 just to avoid a safety audit? This is a huge loophole.

The policy should be changed to require a safety certification for every software change that potentially affects safety. This sounds like a lot of work, but designers have been dealing with this for decades by partitioning vehicle software across multiple independent computers — which guarantees that an update to a non-critical computer won’t affect unchanged critical computers. This is why non-critical updates don’t have to be recertified.

Changing an icon on the radio computer’s display? No problem. Making a “minor” change to the machine-learning data for the pedestrian sensor computer? Sorry, but we want an independent safety check on that before crossing the street in a winter hat.

Philip Koopman is an associate professor in the Department of Electrical and Computer Engineering at Carnegie Mellon University. Michael Wagner is a senior commercialization specialist at CMU’s National Robotics Engineering Center. They are co-founders of Edge Case Research, which specializes in autonomous vehicle safety assurance and embedded software quality. The views expressed here are personal and not necessarily those of CMU.

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Notes: It is important to emphasize that the context for this piece is mainstream deployment of autonomous vehicles to the general public. It is not intended to address limited deployment with trained safety observer drivers. There are more issues that matter, but this discussion framed to fit the target length and appeal to a broad audience.

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How Safe Is The Tesla Autopilot?


It was only a matter of time until there was a fatality involving a "self-driving" car, because no car is likely to be 100% safe.  And it happened in June this year.  This week, Tesla announced a software update involving a number of strategy changes.  https://www.tesla.com/blog/upgrading-autopilot-seeing-world-radar

In this post I'm going to try to take a look at what safety claims can, and cannot, be made for the Tesla Autopilot based on publicly available information.  It's sufficient just to look at what Tesla itself says and assume it is 100% accurate to get a broad idea of where they are, and where they aren't.  Short version: they have a really long way to go to demonstrate they are at least as good as a normal vehicle.

The Math:

First, let's take Tesla's blog posting about the tragic death that occurred in June.
   https://www.tesla.com/blog/tragic-loss
Tesla claims 130 million miles of Autopilot driving, and a US fatality every 94 million miles.

One might be tempted to draw an incorrect conclusion from Tesla's statement that Autopilot is safer than manual driving, because 130 million is larger than 94 million. However, that is far too simplistic an approach.  Rather, the jury is still very much out on whether Tesla Autopilot will prove safer than everyday vehicles.

From a purely statistical approach, the question is: how many miles does Tesla have to drive to demonstrate they are at least as good as a human (94 million mile mean time to fatality).

This tool:  http://reliabilityanalyticstoolkit.appspot.com/mtbf_test_calculator tells you how long you need to test to get a 94M mile Mean Time Between Failure (MTBF) with 95% confidence.  Assuming that a failure is a fatal mishap in this case, you need to test 282M miles with no fatalities to be 95% sure that the mean time is only 94 million miles.  Yes, it's hard to get that lucky.  But if you do have a mishap, you have to do more testing to distinguish between 130 million miles having been lucky, or just reflecting normal statistical fluctuations in having achieved a target average mishap rate.  If you only have one mishap, you need a total of 446M miles to reach 95% confidence.  If another mishap occurs, that extends to 592M miles for a failure budget of two mishaps, and so on.  It would be no surprise if Tesla needs about 1-2 billion miles of accumulated experience for the statistical fluctuations to settle out, assuming the system actually is as good as a human driver.

Looking at it another way, given the current data (1 mishap in 130 million miles), this tool: http://reliabilityanalyticstoolkit.appspot.com/field_mtbf_calculator tells us that Tesla has only demonstrated an MTBF of 27.4M miles or better at 95% confidence at this point, which is less than a third of the way to break-even with a human.
(Please note, I did NOT say that they are only a third as safe as a human.  What I am saying is that the data available only supports a claim of about 29.1% as good.  Beyond that, the jury is still out.)

In other words, they need a whole lot more testing to make strong claims about safety.  This is because it is really difficult (usually impractical) to test safety into a system.  You usually need to do something more, which is one of the reasons why software safety standards such as ISO 26262 exist.

Threats To Validity:

With any analysis like this, it's important to be clear about the assumptions and possible flaws in analysis, of which there are often many.  Here are some that come to mind.

- The calculations above assume that it is more or less the same software for all 130 million miles.  If Tesla makes a "major" change to software, pretty much all bets are off as to whether the new software will be better or worse in practice unless a safety critical assurance methodology (e.g., ISO 26262) has been used.  (In fact, one can argue that *any* change invalidates previous test data, but that is a fine point beyond what I want to cover here.) Tesla says they're making a dramatic switch to radar as a primary sensor with this version.  That sounds like it could be a major change.  It would be no surprise if this software version resets the clock to zero miles of experience in terms of software field reliability both for better and for worse.

- The Tesla is most definitely not a fully autonomous vehicle.  Even Tesla makes it quite clear in their public announcements that constant driver attention and supervision is required.  So the Tesla experience isn't really about fully self-driving cars per se. Rather, it is about the safety of a human+car partnership (Level 3 autonomy in NHTSA-speak). That includes both the pros (humans can react to weird things the software might get wrong), and the cons (humans easily "drop out" of systems that don't require their attention).  If Tesla moves to Level 4 autonomy later, at best they're going to have to make a very nuanced argument to take credit for Level 3 autonomy experience.

- The calculations assume random independent failures, which in general is probably not a good assumption for software.  Whether it is a valid assumption for this scenario is an interesting question.

(Calculation note:  I just plugged miles instead of hours into the MTBF calculations, because the units don't really matter as long as you are consistent.  If you want to translate to hours and back, 30 mph is not a bad approximation for vehicle speed accounting for city and highway driving.  If you'd like 90% confidence or 99% confidence feel free to plug the numbers into the tools for yourself.)

Toyota Unintended Acceleration Case Study Talk Update

My Toyota UA talk from a couple years ago has gotten a lot of views, but watching the video was a bit of a pain because of the proprietary streaming format it was in.

I was finally able to convert the files to .mp4.  So now it's a lot more accessible, especially from mobile devices:
Please see my original posting with more details about various other ways to view and download the materials.

Boehm's Top 10 Software Defect Reduction list

A while back, Barry Boehm & Vic Basili wrote a nice summary of best ways to get better quality software. Their advice still applies to embedded systems today. Below is their list (in bold) with my commentary (the parts not in bold).

1. Finding and fixing a software problem after delivery is often 100 times more expensive than finding and fixing it during the requirements and design phase

Bug fix cost gets worse as your software gets closer to deployment, because you have to not only spend a lot of time tracking down the source of the bug, but also retest the system after the fix.  It is common to find situations in which a bug "escape" into field units costs dramatically more than 100x.  Consider having to recall a fleet of cars to install a bug fix, or do maintenance visits to thousands of sites to manually install a fix.  (Over-the-air fixes have their own problems, but that's a topic for another time.)

2. Current software projects spend about 40 to 50 percent of their effort on avoidable rework.

As the joke goes, the first 90% of the project is spent on design, and the second 90% on debugging.  The cheapest way to debug is to avoid putting the bugs into the software in the first place.  The next best way is to find them at the point of introduction (e.g., peer review of design before code is written) rather than at system test.

3. About 80 percent of avoidable rework comes from 20 percent of the defects

If you have a "bug farm" that's often not because the code is bad, but rather because the underlying requirements and design are bad.  If one module has a lot of bugs you should rewrite the module rather than keep patching it.  However, if during the rewrite you might well discover that the problem isn't really the code, but rather a bad design or unclear requirements. Writing new code for a bad design ultimately won't solve the problem.

4. About 80 percent of the defects come from 20 percent of the modules, and about half the modules are defect free. 

In addition to comments for #3 above, modules with high cyclomatic complexity tend to be difficult to test and tend to be more bug-prone.  Keeping a limit on complexity can help with this problem.

5. About 90 percent of the downtime comes from, at most, 10 percent of the defects.

It makes sense to weight testing on the areas that are the highest risk.  For desktop software this often corresponds to the common use cases.  For embedded systems and other mission-critical systems this also means testing failure detection and recovery for high-cost failures.

6. Peer reviews catch 60 percent of the defects.

Yes, really.  Peer reviews catch the majority of defects.  Why aren't you doing them?  (If you are doing them, are they catching at least half the defects?)


7. Perspective-based reviews catch 35 percent more defects than nondirected reviews.

When you do reviews, give each reviewer a checklist with a different set of areas to think about or different role to play.  For example, control flow, data flow, exception handling, testability, coding style.

8. Disciplined personal practices can reduce defect introduction rates by up to 75 percent.

As much fun as it is to be a coding cowboy, on average even the best programmer will introduce fewer bugs by following a methodical engineering practice rather than slinging code. As mentioned above, the cheapest bugs to fix are the ones that never made it into the code.  Beyond this, there are practices such as PSP and TSP that are shown to dramatically improve quality without really changing productivity.

9. All other things being equal, it costs 50 percent more per source instruction to develop high-dependability software products than to develop low-dependability software products. However, the investment is more than worth it if the project involves significant operations and maintenance costs.

In other words, if a product recall puts your company out of business, it's worth investing in good software quality up front.  In my experience if you are already shipping a mission-critical product you're already spending that 50 percent more (and then some), but still shipping defects.  This isn't saying spend even more.  Rather, doing peer reviews and some other basic software quality practices you can improve quality at the same cost you're already spending.  Testing software into submission is simply not the way to go.

10. About 40 to 50 percent of user programs contain nontrivial defects.

If you have programmable features, your customers will have bugs in what they do.  And don't forget that your financial management spreadsheets are user programs (i.e., can, and often do have bugs).

Items #1 - #10 from:
  Boehm & Basili, Software Defect Reduction Top 10 List, IEEE Computer, Jan. 2001, pp. 135-137.

You can read the original three-page article here:
  https://www.cs.umd.edu/projects/SoftEng/ESEG/papers/82.78.pdf

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Road Warrior Items


This is a different flavor of posting.  For the past couple years I've been on the road a lot and built a collection of useful gadgets to have on a trip.  So here is a product recommendation posting. There might be better alternatives, but these are all items I use on my trips every week. As they say, your mileage may vary.  (If you don't want to read a product list, just skip to this post instead.)  I'll get back to technical posting next time.

GIZMOS

Second screen for my Dell Windows 7 laptop.  Thin and light.  Plugs into USB.  Doesn't need a power brick.  Sorry, but I have no idea how it plays with Mac.
ASUS MB169B

USB charging protector so that when you plug into a rental car it doesn't try to download your phone book, airplanes don't try to connect to your tablet file system, etc.  Or worse, actually attack your phone via juice jacking. This one also supports at least some phone fast charge signals so you get the quick charge rate.  Lots of people use a "c" word to describe this, but better to avoid it to keep the blog safe for mindless nanny filters.
PortaPow USB Block

Travel wireless router.  Input can be wired Ethernet or hotel WiFi.  Output is a Wifi signal that you can use for your multiple devices.  Handy if you want to pay for one internet connection at a hotel and share with multiple devices.  Arguably provides a little more security due to built-in NAT (but not bulletproof). It takes a couple minutes to set it up on a new location, but pretty painless once set up.
ASUS Pocket Router

Power plug adapter. Universal international power adapter that works in every plug I've ever seen.  It's super clever.  (It is a plug adapter, not a voltage transformer.)
Kikkerland UL03 Power Adapter

USB AC charger. Travel size USB power modules so you can keep one in your suitcase. Slightly bigger than the official Apple ones, but a lot cheaper.  110/220V compatible.
USB car charger. For keeping your phone going when you're using it to serve up travel directions
In-ear headset. Noise reducing in-ear plugs with memory foam for a tight fit.  Great for times you don't want an over-hear headset.
Koss ear phones

Over-ear noise cancelling headset.  Yes, this is the one you always see on frequent travelers.  It really does make a difference in reduce wear and tear on your mind from the constant low-frequency roar of jet engines.  You can still hear people talking (although it is reduced; I pull back one ear when talking to a flight attendant).  Gets multiple flights out of a single AAA battery (if you remember to turn it off before you stow it). The one I got came with an iPhone cable so you can also use it for phone calls (or skype) home from a somewhat noisy location.  I like the ones like these that have full ear "cans" that fully cover the ear so they provide noise reduction even when turned off.
 (Bose QC 25)

Laser pointer and slide advance.  Bright green laser pointer, forward/backward buttons for slides shows, and a built-in timer.  I use this every week.
Logitech R800

The charger electronics are the "cheap" type which might have random build quality, but none of the above have given me any problems after significant use.

LUGGAGE, ETC.

Computer travel backpack.  This is the best backpack I have used for laptop and other stuff.  The top zippered compartment is way more useful than I had expected.  Very durable. Love it.  I see it all the time on other frequent business travelers.
SwissGear Blue Ibex backpack

Small rollaboard. This one is perfect for overnight trips on regional jets.  If fits even into the small bins perfectly.  With just a little bit of care it has held up impressively (I wear out bags quickly and this one is holding its own).  A lot lighter than the Tumi rollaboard that it replaced.  Expensive, but long term worth it compared to buying a new bag every 20 trips.

Semi-disposable canvas bags.  Medium-weight drawstring "beach backpack" bags.  Use for light groceries when they charge for bags at checkout, keeping your stuff together if you have your backpack in the overhead, keeping your pillow clean if you need to stash it on an airplane, dirty laundry, etc.  Folds up to be pretty small.  (No doubt plastic ones would fold up smaller, but I like the canvas fabric in this one).  About $3 apiece but you need to buy a dozen at a time.  Alternately bring your favorite beach backpack.
Drawstring Bags

Miscellany bags. Durable small zippered bags to carry USB cables, chargers, tea bags, and so on.
Travel Pouches

Neck pillow.  This is the only travel neck pillow that really works for me on redeye flights. It squishes down to be moderately compact if you put a shoelace or conference tag lanyard around it to tie it up.  I modified it with safety pins holding a small loop of stretchy paracord to keep it closed.  Note that you put the thick end in front under your chin, and put the opening behind your head.
Ergonomic Travel Pillow

Travel liquid containers. Small and easy to squeeze silicone bottles.  Great for shampoo, skin lotion, sunscreen.  Get the 1.25 oz size for carry-on.  They are color coded (mine are green, blue, pink).
iNeibo Bottles

3-D PRINTED

If you like 3-D printing then I recommend the following free designs:

One-piece business card holder: http://www.thingiverse.com/thing:31281

Card case for holding assorted cards not in your wallet:  http://www.thingiverse.com/thing:66327

Travel battery holders (I travel with two AA and four AAA): http://www.thingiverse.com/thing:57281

Cable clip for USB cables: https://www.thingiverse.com/thing:69983

Travel-size toothpaste refill adapter: http://www.thingiverse.com/thing:158910

All of the above will no doubt require the usual fiddling with scaling, but I've found them very useful once I get them the way I like them.

RENTAL CAR INSURANCE

Finally, there is the stress of dealing with the rental car collision coverage dilemma. Do you buy the expen$ive daily collision waiver from the rental company?  If you don't, do you really believe your company will pay out if there is rental car damage? (Depends on your company I'm sure, but I've heard stories of this not working out well.) Or do you take your chances and hope it comes out OK?

For a couple decades now I've carried a Diners Club personal card that comes with primary collision insurance if you use it to pay for the car rental. The US flavor of Diners Club is now just a particular bank logo on an ordinary Mastercard, so acceptance isn't an issue. I've had to use the insurance twice over the years (minor car damage while parked) and no muss, no fuss.  They just took care of it with no deductible.  There are various other cards with various deals. The thing to look for is "primary" (first-payer) coverage. Your other credit card may say it covers rentals, but most of them are "secondary" and thus only pay what's left after your personal car insurance takes care of most of it and you take the hit to your insurance premiums.  I've found that hotel parking lots are particularly dangerous places for scratch-and-dent damage, so worth looking into this.

Here's a good list of credit cards useful for this (I get no compensation from this referral):
    http://thepointsguy.com/2015/07/credit-cards-that-offer-primary-car-rental-coverage/
Most come with annual fee or per-use fee, but if you rent even a few days a year it pays off quickly. Of course it is important to pay attention to which locations are covered if you're traveling away from your home country.

Happy Travels!