A minimum bar, for societal harm, would be against an identical data set of US drivers. The data for human drivers covers vastly more situations than FSD does. FSD refuses to activate in those situations. So an apples-to-apples comparison doesn't exist. The FSD data is effectively cherry picked for ideal driving conditions. Tesla's claims that FSD is safer than the average driver are not supported by their data, and as others have said, either their statisticians are incompetent or liars. This is basic stuff.
However the minimum bar for me to activate it is "compared to me". I've never come close to driving under a truck or into a divider. I slow down driving into the sunset and use a baseball hat if necessary to make sure I can see.
I'll say it again: "compared to what?"