This week NHTSA released a copy of a presentation Honda and VW delivered to regulators in response to a set of driver distraction guidelines (Guidelines for Reducing Visual-Manual Driver Distraction during Interactions with Integrated, In-Vehicle, Electronic Devices) published in September 2014. These guidelines surfaced at the peak of former NHTSA Administrator’s war against distracted driving.

 What are the guidelines and what do they do?

“The purpose of these Guidelines is to reduce the number of motor vehicle crashes and the resulting deaths and injuries that occur due to a driver being distracted from the primary driving task while performing secondary tasks involving the use of an in-vehicle electronic device. The Guidelines are presented as an aid to manufacturers in designing in-vehicle devices that do not allow the performance of tasks that negatively impact a driver’s ability to safely control his or her vehicle. Vehicle and electronic device manufacturers that choose to adhere to these Guidelines do so voluntarily. Compliance with these Guidelines is not required.”

As stated above automakers are not obligated to comply with NHTSA distraction guidelines (note: automakers already use an internally-developed set of similar guidelines). While automakers have no obligation to use NHTSA’s guidelines let alone refute them – that is exactly what Honda and VW did in this joint study.

One key point brought up in the presentation, one that really stuck with me was this:

Available data show that cognitive load from talk/listen cell phone tasks do not increase risk – on the contrary, there is growing evidence that they have a net protective effect.

In other words the data suggest that when talking or listening on a cell phone drivers might actually put aside other more risky behavior.

That begs the question – should we rethink the whole negative reinforcement campaign around texting while driving? Could this data support a pivot from “don’t do it” to “do this instead?” That is rather than encouraging people to not communicate via text while driving, leaving no other option on the table, perhaps NHTSA and other state safety officials consider a “Talk, Don’t Text” campaign.

This sounds like a move backwards in terms of safety, but if we are replacing one very dangerous behavior (eyes off road) for a less dangerous behavior (minor cognitive distraction) – should we?