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Authors. 2) Throws our country far back on quality of manufactured PSE, system of standardization and certification.
MWG. We remind that, according to FL-184, it is forbidden for technical orders to establish requirements to quality of products if it does not influence its safety. The order solves one problem - a problem of safety. The problem of "throws back" as well as "marches forward" is assigned to system of standardization. There are no obstacles to improve it and the order is not exception. According to FL-184, the system of standardization is not within a range of force of the special order, and it is not considered there and should not be considered at all. And really throws our country back the fact that Chiefs of departments issue standards allowing to manufacture products that can lead to massive people deaths. See the example above. Authors in this occasion, for some reason, suggest nothing. Now about system of certification. The authors of the article consider that general (or at least as in the Europe) obligatory certification is a progress and voluntary declaring is regress. We consider as progress balanced interests and requirements and unity of laws and standards for all. Yes, in comparison with the European instruction, the project of the order gives longer list of PSE subjected to declaring but we cannot go by way of simple mechanical comparison. Russia, unlike Europe, has absolutely different certification centers and testing laboratories, they work under absolutely different legal, economic and social jurisdiction. We need not the identity of ways of achieving the purposes of certification (that opponents wish) with Europe but the identity of the results. It is possible to achieve not only through simple equalization of the lists of PSE but through the system approach including all opportunities on this problem with reference to our country. Indisputable remains only one fact - this problem still needs to be worked on.
Authors. 3) Does not meet interests of diligent manufacturers and suppliers of PSE.
MWG. This statement is constructed on previous erroneous statements as on 4-th International conference not everybody but overwhelming majority of manufacturers have agreed with the concept of the project of the order and have publicly declared that. If the authors mean the matters concerning obligatory certification and declaring they were already discussed. The article does not reveal other arguments. The diligent manufacturer, unlike unfair, needs both clear rules of the "game" and diligent "referee". And if there are several legal documents contradicting each other and issued by departmental chefs for one product this circumstance completely suits unfair manufacturers well. As the general remark it would be desirable to draw attention to the fact that the technical order first of all considers interests of the consumer but not the manufacturers, suppliers and certification institutions; therefore, let's re-read once again what the purposes of adoption of technical orders are, and then expose the requirements of manufacturers and sellers in a separate clause.
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