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Is it time to regulate PMRs?

Updated: May 10

Author: Bern Grush


Definition

Public-area mobile robots operate (move and perform tasks) near and among non-involved, unprotected, untrained, and inattentive human bystanders. Such devices may be controlled by:

  • a human controller using remote operation technology;

  • an automated driving system, or ADS, using a combination of on-board, IoT, and cloud technology;

  • a cooperative system that blends these two approaches – (the current start-of-the-art).


It is important that this definition is very broad regarding the purpose, performance and appearance of the technology deployed but very specific about the human attention, proximity, ability, and awareness environment within which it operates. While we expect governments to condition PMR regulatory systems to be constrained by human behaviour and expectations, we cannot expect PMR technology to stabilize in the near future. This means the definition of a PMR is predominantly a definition of the operating environment of these devices and the behaviours we expect from them within those environments rather than a definition of the devices themselves.


Status

In 2024, the state of formal regulations (municipal bylaws, national and regional traffic regulations, operational safety regulations) for PMRs is inadequate to meet municipalities’ needs to determine how or whether to admit this technology on an operational basis—including equitable and safe operation for and among members of the disability community.


It is likely that:

  • many cities will pilot or trial PMRs for delivery, maintenance, passenger, security and numerous other applications;

  • many cities will hesitate to permit many, or any, of these to operate beyond limited trials;

  • many cities that do permit PMR deployment will only permit this under constrained conditions;

  • such conditions as will apply for PMR deployment will frequently be applied because of a lack of certainty about weighing the safety, social, and traffic risks that may appear to apply.


This implies:

  • intended regulatory barriers may be harmful to the social, commercial, and urban values promised by this technology;

  • unintended regulatory consequences may be harmful to these same values.


Taken together, the Urban Robotics Foundation urges governments to carefully examine what should be regulated to maximize the value of and minimize the harm from PMR technology.



Observations

From our study of 26 instances of traffic-related regulations for PMRs from Estonia, Finland, Japan, South Korea and 22 US states, we make the following observations:


  1. To date, national or state regulations regarding PMRs generally describe device dimensions and equipment requirements (e.g., brakes, lights, etc.)

  2. To date, these regulations often mention speed and weight ranges but do not seem to (explicitly) consider momentum implied by a PMR of the maximum allowable weight travelling at the maximum allowable speed. CAUTION: The combination of weight and speed has variable implications on footway, bikeway, and roadway. Cities need safety-related guidelines provided by a state, provincial, or national government.

  3. To date, these regulations do not address certification and licensing matters or device behaviours (beyond weights, dimensions, and speeds). This means that municipalities in the jurisdictions impacted that wish to permit, license, deploy, and/or manage PMRs have device definitions and implied permission to legislate but little or no deployment guidance.

  4. To date, little or no distinction is made between teleoperated (remote-control) and automated (self-guided, “autonomous”) devices. This (correctly) should not matter with respect to the rules for device configurations, speeds and equipment operating within public (pedestrian) spaces. However, this does matter with regard to liability, insurance, appropriate “bystander” warning rules, and numerous other issues.

  5. To date, these regulations specifically apply to “delivery” robots—usually “last-mile goods delivery.” This omits other PMRs of similar size, scale, and momentum, such as maintenance PMRs (sweeping, mopping), security PMRs (surveillance, patrol), or autonomous wheelchair PMRs. This matters if such non-delivery PMRs must cross roadways. It is insufficient to address all PMRs using regulations prepared for delivery PMRs.

  6. To date, PMR regulations have many similarities and some cross-jurisdiction contradictions. They are neither uniform nor harmonized.


Goal

The goal of the URF Regulatory Guide to public-area mobile robots is to:

  • detail the current status of PMR regulation;

  • outline a 3-stage regulatory model; and

  • develop the ways in which draft ISO 4448 can contribute to this model.


The three stages of PMR regulations:

  • Stage 1 – model definition suitable for traffic legislation (derived from the current 26+ instances);

  • Stage 2 – detailed deployment rules and behaviours (using draft standard ISO 4448 as guidance);

  • Stage 3 – rules for certification (licensing guidance would follow from this).


Further Information

Contact the Urban Robotics Foundation for further information, and follow our newsletter for further updates.

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