«Working clothes and personal safety equipment» № 4(35), 2006, p.20

A.V. Lyang - expert of JSC "Sorbent"

I.G.Malik, V.L.Smolin. - experts of Joint-Stock Company «Sorbent - Center Of Introduction»

DISCUSSION? LET IT BE SO!

we discuss the project of the special technical order "About requirements to personal safety equipment

The "Working cloths and personal safety equipment" magazine has published an article in September - the invitation to the open discussion under the project of the special technical order "About personal safety equipment". Authors of article - experts from JSC's "Sorbent" Lyang A.V. and "Sorbent - Center Of Introduction" Malik I.G., Smolin V.L.

Well, discussion is a good business; people say that truth is born from a dispute... But before we start to discuss let's arrange some rules. They are simple: scientists and experts, unlike politicians, argue with facts, documents, results of researches, calculations, etc.

Necessity to agree the rules is caused by the fact the mentioned article does not give a single hint about demonstrative base that is quite pardonable for an average citizen but is absolutely intolerable for experts or scientists. So, first line of the article says that the order being discussed "will be approved (it's interesting who exactly approves laws in Russia if, according to the Constitution, the State Duma adopts them and the President ratifies?) in no time, possibly this year". Authors do not inform us what source such a strange words are taken from. In reality terms of development of the project of the order are established in the PROGRAM OF DEVELOPMENT OF TECHNICAL ORDERS adopted by the Government of the Russian Federation in May, 29th, 2006 № 781-r which states that the given order has to be developed and presented (not adopted!) to the Government only in September, 2008. We should agree that the time difference between the end of the year 2006 and the autumn of 2008 is considerable. What for was it necessary to mislead readers we do not know.

Next. Pilot project of the order being discussed by the authors of the article was sent only to the members of Association PPE (83 member companies) for arrangement and to some public institutions (4 member organizations) that are involved in technical regulation process for advice. The article does not explain why the authors took the liberty of putting, per se, internal document (draft if you like) of the Association PPE to All-Russian discussion. We may notice that while working there were more than 20 readings of the project proposed. There is no saying which one of them the authors decided to put on table for public. Furthermore, authors proposed to discuss just randomly selected clauses but not the whole project. Nevertheless, the discussion has been offered and we will try our luck on it.