Guest Column: Self-driving safety expert Camilla Fowler on assured operations – why great vehicles alone are not enough

Guest Column: Camilla Fowler
Look beyond vehicle safety to assured operations, Fowler advises local authorities

Editor’s comment: “An expert in self-driving safety, Camilla led TRL’s risk management team for the pioneering HelmUK HGV platooning trial. More recently, she was part of the Oxa team which facilitated a first on-road self-driving experience for Meera Naran MBE and my good self.

“Now at consulting firm WSP, she is driving awareness of the new APS permitting scheme, encouraging local authorities to prioritise organisational safety and governance. Alongside continuous improvements in vehicle design and behavioural safety, moving to broader assurance is the next big step.”

Self-driving expert Camilla Fowler, Technical Director, Network Operations, WSP
Self-driving expert Camilla Fowler, Technical Director, Network Operations, WSP

A pivotal moment for AV safety

Automated transport is reaching a pivotal moment. After decades of investment, research and pilot projects, automated driving systems (ADSs) are moving beyond trials and into live operation. Driverless passenger services are being prepared for public roads, while automated vehicles already operate in ports, airports, mines, logistics hubs and industrial sites.

In the UK, the Automated Vehicles Act 2024 (AV Act) and the new Automated Passenger Services (APS) permitting scheme signal a shift from experimentation to real-world deployment. For local authorities, that shift brings a new responsibility: deciding whether automated services can operate safely and acceptably in real places, not just whether the vehicles have been technically approved.

Here, automated vehicles on public roads are being assessed through type approval and vehicle authorisation, supported by secondary legislation under the AV Act. The APS scheme creates a route for automated passenger services to move from trial and demonstration into deployment. These mechanisms provide important assurance at the point of approval but say less about how safety should be maintained throughout the life of a service. Compliance remains essential, but compliance alone does not guarantee safety.

Organisations fail before technology

Evidence from real-world deployments provides important lessons. The 2018 Uber fatality in Tempe is often viewed as a technology failure, yet investigations highlighted organisational shortcomings, including weaknesses in safety culture and risk management. Similarly, the suspension of Cruise’s operations in 2023 reflected wider concerns around incident management, transparency and regulatory engagement.

The common thread is that technology did not fail in isolation. Failures emerged because the organisations responsible for deploying and operating it lacked the governance, accountability, controls and safety culture required to manage risk effectively.

The same pattern can be seen off-road. WorkSafe Western Australia’s investigation into a collision between an autonomous truck and a manned water cart identified weaknesses in site controls, change management, communications and mixed-traffic management.

Across sectors, the conclusion is remarkably consistent: organisations often fail before the technology they deploy does.

A new safety challenge

One of automation’s most significant consequences is that responsibility for safety shifts away from individual drivers and towards organisations. In conventional transport, safe operation relies heavily on the competence and judgement of the driver. In automated transport, that responsibility is distributed across organisations.

For public road services, three roles are increasingly emerging:

  • Technology providers, who develop and maintain the ADS.
  • Fleet operators, who manage day-to-day operations.
  • Platform providers, who coordinate service delivery and customer interactions.

These roles may sit within different organisations, creating interfaces where responsibilities can become blurred and risks can emerge. The challenge is not simply to define accountability within each organisation; it is to manage safety across organisational boundaries.

Major failures rarely originate within a single component. They emerge from breakdowns in communication, coordination and decision-making.

What good looks like

To address this challenge, the industry needs a broader understanding of safety. Safe deployment depends on more than vehicle design and performance. It requires a system-level perspective across assurance domains:

  1. Behavioural safety – validating safe and lawful behaviour.
  2. Operational safety – managing safety in live operations.
  3. Organisational safety – creating the conditions that sustain safety over time.
  4. Safety governance – coordinating safety across organisations and interfaces.

Weakness in any one of these areas can undermine the safety of the whole system.  This means viewing AVs not as standalone products but as components within wider transport and operational systems.

Place-based safety: AV considerations in smart cities very different to rural deployments
Place-based safety: AV considerations in smart cities are very different to rural deployments

Under the APS permitting scheme, local authorities may receive applications for automated passenger services and be asked to consent to them. This is not simply a decision about whether a vehicle is technically safe or legally authorised to drive itself. It is a place-based operational judgement about whether the proposed service can operate safely, inclusively and acceptably within the local transport system.

Authorities will need to consider integration with public transport, kerbside management, emergency response, accessibility, safeguarding, network impacts and wider transport objectives. That makes APS consent an important part of deployment safety, not a narrow technical approval process.

The same principle applies in industrial environments, where automated vehicles must be integrated into existing site operations, workplace safety controls, maintenance processes and mixed-traffic environments.

From approval to assured operation

The industry’s next challenge is moving from approval to assured operation. Operational safety requires continuous monitoring of real-world performance, identification of emerging risks, management of incidents and near misses, maintenance of technical integrity and assurance that systems continue to operate within approved limits.

Equally important is organisational safety: effective safety management systems, strong leadership, transparent reporting cultures, robust change management and continuous learning. Organisations must be able to balance commercial pressures with safety responsibilities, while ensuring concerns can be raised, investigated and acted upon.

Bridge to the future – managing AV risks on highway in mixed traffic
Bridge to the future – managing AV risks on highway in mixed traffic

Alongside these capabilities sits safety governance: the structures that enable organisations to share information, escalate risks, coordinate interventions and make safety-critical decisions across complex operating models.

These disciplines are commonplace in aviation, rail, nuclear and other high-hazard industries. Automated transport needs a comparable framework so services can operate safely, scale responsibly and generate lessons for future deployments.

The opportunity ahead

The next phase of automated transport will not be defined by whether the technology works, but by whether organisations are ready to operate it safely. Success will depend on operators, local authorities, infrastructure owners and regulators building the capability to manage automated transport in live, changing environments and at scale.

That means treating operational readiness as seriously as technical readiness: establishing governance before deployment, monitoring performance in use, learning from incidents and near misses, clarifying responsibilities and integrating automated transport into existing transport and safety systems from the outset.

Safe vehicles are essential, but they are not enough. The future of automated transport will be secured by organisations that can operate, govern and learn safely.

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