Authors. Clause 1.1 of the new project does not consider basic requirement of Clause 7 of the Federal law in technical regulation that technical orders establish minimal requirements counting degree of risk to be damaged.

Members of working group (MWG). Working group of Association PPE has no common practice to determine, especially upon its own discretion, what in the Russian laws is "basic" and what is not. Clause 1.1 of the project that shows purposes and scope of the order has not a single word, indeed, that the requirements are established counting degree of risk. It was made because such requirement is already written down in the Federal law № 184-2002 and is obligatory for execution regardless of the fact that it is written down in other laws or not. The project of the order cannot be quotation-book of other laws including FL-184. Unfortunately, authors do not confirm necessity of repeated record of this requirement to this particular order. On the other hand there is still neither the methodical solutions nor recommendations nor suggestions (including authors) how the degree of risk should be considered. It turns so that even if it is put to the law it is impossible to follow it upon this matter. We should say that this is one of the points of the Federal Law "About technical regulation" being criticized but that's other topic. If authors mean the division of personal safety equipment similar to mentioned in the European Instruction 89/686/EEC - by three directions - there it is made for the purposes of certification, instead of establishing concrete safety requirements to protective equipment.

Authors. Clause1.4 of the new project is in complete contradiction with p. 7.3 of the Federal law on technical regulation, viz force of the new project does not extend on operation, manufacture, transportation, storage and recycling of PSE.

MWG. Authors of remarks misinterpreted, as usual, clause 7.3 of the Federal law "About technical regulation". The clause says: "Technical order should contain complete list of products, processes of manufacturing, operating, storage, transportation, sales and recycling that come within its requirements (we stress upon this) and rules of identification of object of technical regulation with the purposes to use the technical order". Virtually, it is the list of objects of regulation being allowable to establish requirements within the limits of any special order but not the binding list that should be in every order. For instance, it is absurd to settle requirements for storage and transportation in the order concerning safety of buildings and constructions. In connection with the fact that the project it not an abstract order but SPECIAL, authors followed clause 8, p. 5 of the FL-184. Mentioned clause obliges to establish requirements only to objects that are not within requirements of other technical orders or laws. In our case, for example, PSE containing dangerous chemical substances are produced, transported, utilized according to requirements of the technical order "About safety of chemical products, processes of their storage, transportation, sales, use and recycling". Laws should not duplicate or quote each other.