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We will drop the points connected with history and necessity (or unnecessity) of the technical reform, its importance (or unimportance), since they were clarified by executive and legislative institutions of Russia many times and it is easy to find them and discuss in a press. It would not be desirable to discuss the project of the order "About PSE" developed by ТC-320 (Thesis Committee) since it was discussed in public and the reasons not allowing it to be adopted also are known. It will be mentioned only in context of the thesis about necessity of harmonization of the Russian technical laws with the European ones and desire of the authors of the article to present it as an exemplary project of the technical order. We have to notice that the term "harmonization" has no clear definition still. Automatically we start to be jealous of people who easily find out which document is harmonized and which is not... Surprisingly: Europeans whom actually our documents should be harmonized with still have debates upon this matter. Western technical journals are full of problem scientific articles about harmonization and also do not have its clear definition. In our case, judging from unappealable statement that the project of order ТC-302 is in complete harmony with the known European Instruction there is only one conclusion: authors of this statement are slightly mistaken because the project of the order developed by ТC-320 IS NOT HARMONIZED with the European Instruction 89/686/EEC, but IS IDENTICAL to it. You may agree that "harmonicity" and "identity" are words of different meanings. Not to get addicted to polemics upon irrelevant topic we can only say that legal documents of the state first of all should be in correspondence with the laws of the own country and after that with laws of others if it is possible for any extent. We will just draw attention to the fact that document being slightly liberal and supplemented translation of the European Instruction (that actually is project ТC-320) into Russian cannot be named special technical order. And if and someone "has fancied" foreign document the legislative base of the Russian Federation has other way of its adoption - by signing international treaties and agreements but not by the way of translating it into the native language and presenting as the "own" document. Further authors for some reason essentially distort the process and history of development of the project of the order by Association PPE. As they say, the project, in the form of document somehow acceptable for discussion as the concept, has been developed not in the year of 2005 but by the middle of 2006. And the project was developed not only by one member organization of Association but constantly involved experts from seven and more member organizations ("more" means that there was a necessity to attract additional experts). Further our discussion will continue as follows: we will list debatable, in authors' opinion, clauses and regulations from the project of the order stated by the authors themselves and suggest our opinion upon the given matter. |






