Pretty damn sure. Even if an engineer drives his normal car to work, hops in a waymo car, and drives 9-5, and then drives a normal car back home, they've already constructed a scenario that is heavily time-weighted towards lighter than human-representative traffic experiences. Even small biases that you don't even think are meaningful can have a big impact on outcomes.
But it doesn't stop there. Google hasn't tested snow at all. I'd be surprised if their testing locations represented rainy weather that is representative for more than 10% of the US. They don't test freeways, and by extension, do not test onramps and offramps. In California, they don't even go over 25 mph. Under those conditions they have been ostensibly pretty good at not causing accidents, but how good are they at avoiding accidents that are not their fault? This means accidents caused by other drivers and acts of god. Safety is far more than just causality.
But more importantly, their miles traveled very easily exclude small snippets of time where an engineer takes over, but still counts the rest of the journey where the computer did fine. How representative is that? How good are humans when we let jesus take the wheel the moment driving gets slightly complicated? If a human overrides the computer only 1% of the time, that could still be anywhere from 1% to 100% of trips with at least one human override.
It's very easy to catastrophically mislead yourself when working with averages [0]. Statisticians and Economists go through absolutely absurd lengths to make comparisons robust. Even if we had access to 100% of the data on Waymo's self driving cars, I don't know a single statistician that would be comfortable making a comparison to extremely coarsely aggregated data on human driving. Only through extensive testing in situations that are representative of how humans (and not just test engineers) drive will we be able to conclude that one is safer than the other. And that's why Phoenix is important to Waymo.
[0] https://www.google.com/search?client=ubuntu&channel=fs&q=the...