Overall my reaction to this doc is pleasant surprise, and I think this proposal takes AI progress and risks seriously, including more "far out" risks from recursive self improvement and loss of control. The writing style, with some exceptions, mostly steers clear of generic corporate gov affairs lobbying speak and takes stands on specific issues in a way that is refreshing for someone who has to read a lot of these sorts of documents.
I definitely have qualms and objections - most notably on preemption (which is not a small objection!) - but relative to many past OpenAI Global Affairs docs I can recall it is a huge improvement that reads much more consistently with conversations I have with technical AI researchers at OpenAI and other companies.
Incomplete list of things I like:
• The section on building up CAISI is strong and sensible. The EO creates a lot of new responsibilities and need for coordination between companies and national security functions in the government, which is a great time to revisit ensuring that CAISI is appropriately resourced and empowered to provide in house frontier AI expertise.
• Discussion of the importance of international collaboration on AI safety. Some of the language here is very direct and clear-eyed about the potential for extreme risks "Particular priority should be given to developing shared approaches for evaluating and responsibly communicating progress toward recursive self-improvement (RSI), where a lack of shared measurements and transparency could intensify competitive pressures among developers and make it more difficult to determine when additional safeguards are warranted."
• The proposal mentions risks from recursive self-improvement fifteen times! This risk vector is something that is taken extremely seriously among the labs, but largely has not penetrated as much into DC world. It is important that it does!
• OpenAI explicitly rejects liability safe harbors, saying "liability frameworks should preserve accountability for severe harms and should not provide blanket safe harbors from responsibility." Particularly notable given OpenAI's prior support for a liability safe harbor in Illinois.
What I don't like:
• The main area where I have objections, which is not a small issue, is on preemption. It could be worse - the proposal goes into detail on what a frontier safety framework needs to include. Most of this is stuff that is in SB 315, but not all of it is, and the document explicitly makes clear that any federal standard that preempts the states on frontier safety needs to go well beyond SB 315. This is much better than preempting with nothing, or preempting with just SB 315. However, I still think that taking away state authority on protecting their citizens from these risks is a really dangerous idea that risks concentrating enforcement in a single point of failure, and removing the ability of legislatures to continue to adapt in response to new developments that will inevitably occur. We should be building and maintaining state capacity on these issues at both the state and federal level to address these issues. I also find their repeated invocation of the concept of "reverse federalism" kind of cringy and annoying - it seems like its just OpenAI putting a new spin on states passing laws and the federal government considering those proposals in what it does. Isn't that just normal federalism?
Concluding thoughts:
As always, the most important question will be in the follow through. These policy documents are always necessarily going to be high level and leave room for considerable interpretation into how they are translated into legislation. For instance, consider the language on rejecting liability safe harbors - which says it should avoid "blanket safe harbors" for "serious harms." If interpreted narrowly, this could still be consistent with narrower safe harbors that would still be quite harmful policy.
OpenAI's policy work contains multitudes - on one day they support good legislation like SB 315 (which is the first bill in the US to mandate third party audits), on another day they subpoena Encode and myself for all our communications on SB 53 or support a brazen liability shield in Illinois. The trend is recently positive for OpenAI's in house policy work, though I will view their support of SB 315 quite differently in retrospect if it is used as justification for a deeply inadequate preemption regime. Of course in addition to the in-house policy work, Leading the Future is another matter, see e.g. the new astroturfing allegations that came out today.
I do think this document is perhaps most notably good in the ways that it seems willing to look a little bit weird while explaining some of the sorts of risks that are commonly discussed and taken very seriously within labs, but are not as discussed within DC. Normalizing discussion of these concepts is a very valuable contribution.
Overall a lot to like, also important things to dislike or be skeptical of. I recommend reading in full, and curious for other folks thoughts.
Very excited about this to be out, and to hear feedback! I think there is a lot of good stuff in here, from expanded role of CAISI, to RSI safety, to more nuanced stance on preemption, and much more.