The following information is essential, first of all, for the organizations, which develop special technical specifications.
It is not a secret that the normative documents regulate a mandatory approval of special technical specifications by the Russian Ministry of Emergency Situations, and the Ministry of Construction of the Russian Federation.
Nevertheless, a few people know the very core of the issue and the procedure within the ministries, because internal regulatory documents are not reported to ordinary citizens, although they are of no secret.
In the Ministry of Construction of the Russian Federation there is a transparent system, that implies arranging councils, where all the documents are examined.
The completeness of the documents as well as the quality of decisions made and the reasons for the special technical specifications development are checked beforehand.
Everybody must have read the guidelines for the special technical specifications creation, departmental documents regulating the conduct of councils, the procedure for STS approval. However, most people usually face up to refusals to approve special technical specifications.
There are many reasons for such refuses, for example, EMERCOM of Russia regulations contradict the norms of Russian Ministry of Construction (these two departments do not conform the internal documents with each other, although the order of EMERCOM, regulating the approval procedure should be coordinated with the Ministry of Construction as it is a document, extending approval in the Ministry of Justice of Russia). Another reason for refusal is a subjective opinion of the experts, who consider special technical specifications; and a subjective opinion of the members of Regulatory and Technical Council.
We know that many of you face the problem of the Refusal letters from the Ministry of Construction of Russia. One should understand that sometimes the Ministry of Construction receives such documents, that an expert understands that it more like an essay than special technical specifications. Then he faces up to the problem of formulating the exemption material to describe problems (in special technical specifications), that should be solved; and often the Refusal letter is the same size as special technical specifications.
The situation is also exacerbated by the fact that the amount of material entering the Russian Ministry of Construction is not comparable with the number of experts to consider them. As a result, a developer is waiting for special technical specifications approval for months, and then he receives Refusal letter. We suggest to remove these contradictions before sending the documents to EMERCOM of Russia, and are ready to help you in expertise of special technical specifications, thus, avoiding unnecessary refusals and saving your time and money.