Cassazione Penale, luglio 2020 – Condanna Medico Competente. Nesso di causalità tra condotta omissiva del M.C. e decesso del lavoratore

Presidente: CIAMPI FRANCESCO MARIA Relatore: TORNESI DANIELA RITA

Data Udienza: 21/01/2020

Fatto

1. Con sentenza del 23 maggio 2018 il Tribunale di Como dichiarava C.V., nella qualità di medico del lavoro, responsabile del reato di cui all’art. 590 sexies cod. pen. (così riqualificata l’originaria imputazione di cui all’art. 589 cod. pen.) in danno di A.M. e lo condannava alla pena, condizionalmente sospesa, di anni uno di reclusione. Il C.V. veniva condannato al risarcimento dei danni in favore delle parti civili Omissis M. da liquidarsi in separata sede, con l’attribuzione di una provvisionale di euro 50.000,00 in favore di ciascuna di esse.

1.1. In particolare al predetto imputato, nella qualità di medico del lavoro, era ascritto di aver cagionato, per colpa consistita in negligenza, imperizia ed imprudenza ed inosservanza delle regole che presiedono l’arte medica, la morte di A.M., dipendente della ditta Cappellini con sede in Mariano Comense, avvenuta in data 13 luglio 2014:

– per avere omesso, nel redigere i certificati di idoneità lavorativa del 12 dicembre 2012 e del 12 dicembre 2013, di effettuare un’adeguata valutazione dei risultati degli esami ematochimici del 18 dicembre 2012 e del 16 dicembre 2013 con specifico riferimento alle alterazioni della crasi ematica che presentava evidente leucopenia, lieve anemia, piastrinopania, pancitopenia, linfocitosi con segnali di evidente peggioramento rispetto agli esami precedenti;

– per aver omesso qualunque informazione e comunicazione dell’esito degli esami sopraindicati al diretto interessato e al medico curante, determinando così un ritardo diagnostico della patologia (mielodisplasia) della quale il A.M. era affetto da almeno due anni compromettendo così le possibilità di intervento terapeutico che avrebbero potuto allungarne la durata della sopravvivenza e migliorare la qualità della vita.

2. Con sentenza del 12 febbraio 2019 la Corte di Appello di Milano, in parziale riforma della pronuncia di primo grado, concesse le attenuanti generiche, ha ridotto la pena a mesi otto di reclusione.

3. Secondo la ricostruzione operata dai giudici di merito il C.V. è incorso in un errore diagnostico per non avere correttamente valutato, per colpa, la gravità del quadro clinico emergente dalle visite periodiche eseguite negli anni 2012 e 2013 e, in particolare, dagli esami ematochimici da cui risultava una grave forma di leucopenia e di piastrinopenia con inversione della formula leucocitaria, e, conseguentemente, per non avere comunicato al lavoratore e al medico curante la situazione allarmante sul suo stato di salute che di lì a poco si sarebbe manifestata, in forma conclamata, nella malattia (mielodisplasia) che ne ha cagionato la morte, il cui ritardo diagnostico ha compromesso la possibilità di un intervento terapeutico che gli avrebbe quantomeno procrastinato l’esito infausto.

Viene rimproverato al C.V., in presenza del predetto quadro clinico, di avere sottovalutato le condizioni del lavoratore, quanto meno pre – patologiche, che imponevano lo svolgimento di ulteriori accertamenti sanitari e di non avere espresso un giudizio di inidoneità al lavoro.

4. C.V., a mezzo del difensore di fiducia, ricorre per cassazione avverso la predetta sentenza lamentando, con un unico motivo, il vizio motivazionale e l’inosservanza e/o erronea applicazione di legge.

Nel contestare la sussistenza dei profili di condotta colposa addebitati a suo carico, sostiene la correttezza del suo operato per essersi accertato dello stato di salute di A.M., nell’ambito dei compiti al medesimo assegnati, in relazione alla sua qualifica di medico competente, e di avere correttamente formulato i giudizi di idoneità al lavoro tenendo conto delle mansioni che gli risultavano anche da quanto riferitogli direttamente dal datore di lavoro (ovvero, di addetto alle operazioni di banco, montaggio di cassetti, assemblaggio ed imballaggio). Sottolinea di essersi premurato di avere riferito al A.M. di rivolgersi al medico curante per effettuare ulteriori accertamenti clinici. Rappresenta che la Corte distrettuale non ha tenuto conto delle risultanze istruttorie del giudizio di primo grado che escludevano la sussistenza del nesso di causalità tra la condotta tenuta dall’imputato e l’evento morte. Afferma che non gli è imputabile alcun errore diagnostico per non avere riscontrato la displasia midollare da cui era affetto il lavoratore (malattia ematologica e non oncologica), i cui sintomi si erano manifestati solo alla fine del mese di aprile 2014.

Rileva l’erroneità del giudizio controfattuale operato nella sentenza impugnata che risulta contrastante con le risultanze processuali.

Sottolinea, infine, quanto al trattamento sanzionatorio, che la Corte distrettuale gli ha concesso le attenuanti generiche in relazione all’avvenuto versamento della provvisionale in favore delle parti civili (il che non può essere considerato quale ammissione di responsabilità) e non per i motivi invocati nell’atto di appello ove veniva chiesto di valutare il grave comportamento doloso tenuto dalla persona offesa ai fini dell’applicazione delle circostanze di cui all’art. 62 n. 5 cod. pen.

4.1. Conclude chiedendo, in via principale, l’annullamento della sentenza senza rinvio con conseguente assoluzione di C.V. dal reato contestatogli e con rigetto della costituzione di parte civile, con ogni conseguenza di legge, o in subordine con l’annullamento della sentenza impugnata con rinvio ad altra sezione della Corte di appello di Milano.

Diritto

1. Il ricorso è fondato nei termini che seguono.

2. Le questioni sottoposte all’esame del Collegio impongono di procedere all’esatta delimitazione del ruolo assegnato al medico competente nell’ambito dell’organizzazione aziendale.Tale figura professionale ha fatto la sua comparsa nel nostro ordinamento con l’art. 33 del d.P.R. n. 303 del 1956per essere poi delineata ulteriormente dagli artt. 95 – 98 del d.P.R. n. 320 del 1956concernente l’assistenza relativa a lavoratori esposti a sostanze tossiche o infettanti o che risultassero comunque nocive. In seguito con l’art. 2 d.P.R. n. 962 del 1982 e con l’art. 15 d.lgs. n. 277 del 1991 il predetto obbligo di sorveglianza sanitaria veniva esteso a tutte le aziende che esponevano i lavoratori ad agenti chimici, fisici e biologici durante il lavoro. Con il d.lgs. n. 626 del 1994 (artt. 3 e 7) il legislatore ha stabilito la generalizzazione di tali attività in tutte le aziende c.d. a rischio.

Il d.lgs. n. 81/2008 ha stabilito una ancora più organica disciplina normativa dei garanti della sicurezza sul lavoro, ivi compreso il medico competente, quale collaboratore che coadiuva l’imprenditore nell’esercizio dei suoi obblighi prevenzionali, in quanto portatore di qualificate cognizioni tecniche e, dunque, nell’ambito di un rapporto di natura privata e, al contempo, con un ruolo contraddistinto da connotati di natura pubblicistica in quanto è tenuto ad operare con imparzialità nell’ottica esclusiva della tutela dell’integrità fisica dei lavoratori.
Anche a seguito della riforma avvenuta con il d.lgs. n. 106/2009 i compiti del medico competente si suddividono essenzialmente in tre categorie:

a) i compiti c.d. professionali costituiti essenzialmente dal dovere di effettuare la sorveglianza sanitaria, ovvero l’insieme degli atti medici finalizzati alla tutela dello stato di salute dei lavoratori, in relazione all’ambiente di lavoro, ai fattori di rischio professionale e alle modalità di svolgimento dell’attività lavorativa.

b) i compiti c.d. collaborativi rappresentati dal dovere di cooperare con il datore di lavoro alla programmazione del controllo dell’esposizione dei lavoratori ai rischi. La partecipazione del medico competente alla fase di valutazione dei rischi aziendali garantisce allo stesso un’approfondita conoscenza dell’organizzazione dei processi lavorativi e gli consente, conseguentemente, di fissare adeguate misure di prevenzione ed efficaci protocolli sanitari; nell’ambito di tale attività occorre un suo coinvolgimento, da parte del datore di lavoro, anche nella redazione del documento di valutazione dei rischi e nella agevole individuazione delle possibili cause di eventuali disturbi riferiti dal lavoratore;

c) i compiti c.d. informativi consistenti: – nel dovere primario di informare i lavoratori sul significato della sorveglianza sanitaria e, nel caso di esposizione ad agenti con effetti a lungo termine, sulla necessità di sottoporsi ad accertamenti sanitari anche dopo la cessazione dell’attività; – nel dovere di fornire, a richiesta, informazioni analoghe ai rappresentanti per la sicurezza dei lavoratori; – nel dovere di esprimere per iscritto, in occasione delle riunioni di cui all’art. 35 (riunioni periodiche, obbligatorie nelle aziende con più di 15 dipendenti aventi ad oggetto il tema della sicurezza), al datore di lavoro, ai rappresentanti dei lavoratori per la sicurezza, i risultati anonimi collettivi della sorveglianza sanitaria effettuata e fornisce indicazioni sul significato di detti risultati ai fini della attuazione delle misure per la tutela della salute e della integrità psico – fisica dei lavoratori.

2.1. Tra gli obblighi ex lege incombenti sul medico competente risulta di fondamentale rilievo la programmazione e lo svolgimento della sorveglianza sanitaria attraverso protocolli sanitari, calibrati sui rischi specifici, tenendo conto degli indirizzi scientifici più avanzati e dello stato generale di salute del lavoratore (cfr. artt. 38 e segg. del d.lgs. n. 81/2008).

In particolare la ratio sottesa all’art. 41 del predetto decreto legislativo è quella di prevenire qualunque forma morbosa provocata dal lavoro ed è mirata alla formulazione di un giudizio di idoneità alle mansioni specifiche che tenga conto di tutte le caratteristiche psico – fisiche del lavoratore confrontate con il peculiare contesto ambientale.

In tale ottica la predetta disposizione impone, tra l’altro:

-la visita medica preventiva intesa a constatare l’assenza di controindicazioni al lavoro cui il lavoratore è destinato in relazione alla mansione specifica;

-la visita medica periodica per controllare lo stato di salute dei lavoratori ed esprimere il giudizio di idoneità alla mansione specifica, stabilita di norma, in una volta l’anno, ma che può assumere cadenza diversa stabilita dal medico competente in funzione della valutazione del rischio; l’organo di vigilanza, con provvedimento motivato, può disporre contenuti e periodicità della sorveglianza sanitaria differenti rispetto a quelli indicati dal medico competente;

-la visita medica, su richiesta del lavoratore, al di fuori dai controlli periodici, qualora sia ritenuta dal medico competente correlata ai rischi professionali o alle sue condizioni di salute, suscettibili di peggioramento a causa dell’attività lavorativa svolta, al fine di esprimere il giudizio di idoneità alla mansione specifica;

-la visita medica in occasione del cambio della mansione onde verificare l’idoneità alla mansione specifica;
-la visita medica alla cessazione del rapporto di lavoro nei casi previsti dalla normativa vigente. Tali visite devono essere svolte secondo i canoni classici della semeiotica, della raccolta approfondita dell’anamnesi, di un attento e mirato esame obiettivo e con lo svolgimento degli esami clinici e biologici ritenuti necessari. Inoltre, per alcuni rischi lavorativi, regolamentati da apposite leggi, esistono protocolli diagnostici minimi obbligatori, comunque implementabili a giudizio del medico competente. Per la maggioranza dei rischi, invece, la scelta di accertamenti complementari è lasciata alla valutazione del medico cui spetta di non trascurare l’esecuzione delle indagini utili per una diagnosi precoce, anche in periodo preclinico, di eventuali malattie professionali, e, nel contempo, constatare il permanere delle condizioni di sopportabilità del rischio.
All’esito il medico competente esprime uno dei seguenti giudizi relativi alla mansione specifica:
a)idoneità; b) idoneità parziale, temporanea o permanente, con prescrizioni o limitazioni c) inidoneità temporanea; d) inidoneità permanente.

Avverso tali giudizi è ammesso ricorso, entro trenta giorni, all’organo di vigilanza territorialmente competente che dispone, dopo eventuali ulteriori accertamenti, la conferma, la modifica o la revoca del giudizio stesso.

2.2. L’art. 58 del d.lgs. n. 81/2008 delinea il quadro generale delle sanzioni, penali ed amministrative, che si pongono a presidio e a completamento della complessa disciplina delle attribuzioni e funzioni proprie del medico competente.

Fatta eccezione per l’illecito commissivo introdotto dal d.lgs. n. 106/2009 (ovvero l’effettuazione di sorveglianza sanitaria per accertare stati di gravidanza o negli altri casi stabiliti dalla legge) gli illeciti contravvenzionali previsti da tale disposizione sono di pura omissione in quanto puniscono il mancato assolvimento dei singoli obblighi gravanti sul medico e previsti dal correlato art. 25.

2.3. Oltre che di tali reati propri, il medico competente risponde, nella qualità di titolare di un’autonoma posizione di garanzia, delle fattispecie di evento che risultano di volta in volta integrate dall’omissione colposa delle regole cautelari poste a presidio della salvaguardia del bene giuridico – salute dei lavoratori – sui luoghi di lavoro, direttamente riconducibili alla sua specifica funzione di controllo delle fonti di pericolo istituzionalmente attribuitagli dall’ordinamento giuridico.

3.Tanto premesso, va anzitutto evidenziato, in punto di fatto, che, per quanto emerge dalle sentenze di merito, il C.V. aveva provveduto a consegnare i risultati delle analisi cliniche e in particolare degli esami ematologici al A.M. consigliandogli di recarsi dal medico curante per ulteriori approfondimenti diagnostici mentre quest’ultimo non aveva dato alcun seguito a tali indicazioni. È opportuno precisare che non è prevista, al riguardo, alcuna interlocuzione diretta da parte del medico competente nei confronti del medico curante del lavoratore, cosicché nessun rimprovero a tale titolo può essergli addebitato.

3.1. Ciò posto, il ragionamento sviluppato dalla Corte distrettuale e posto a fondamento della statuizione di condanna risulta affetto sia dal vizio di violazione di legge che dalle dedotte inconferenze motivazionali.

Ed invero, non risulta adeguatamente sviluppato il tema volto a verificare se, nello svolgimento delle visite periodiche eseguite dal C.V. negli anni 2012 e 2013 nei confronti del A.M., sulla base delle effettive conoscenze, sia cliniche che di lavoro, o, comunque, di quelle conoscibili, e nella correlata formulazione dei relativi giudizi di idoneità alle mansioni specifiche, sia ravvisabile, a suo carico, la sussistenza di una condotta colposa tenuto conto dei doveri cautelari attribuitigli dall’ordinamento giuridico in ragione della sua specifica posizione di garanzia rivestita.
Va in ogni caso considerato che il presupposto della rimproverabilità soggettiva nei confronti dell’imputato implica la prevedibilità dell’evento che va compiuta ex ante, riportandosi al momento in cui la condotta è stata posta in essere avendo riguardo anche alla potenziale idoneità della stessa a dar vita ad una situazione di danno e riferendosi alla concreta capacità del soggetto di uniformarsi alla regola cautelare, da commisurare al parametro del modello dell’homo eiusdem professionis et condicionis, arricchito dalle eventuali maggiori conoscenze da parte dell’agente concreto (Sez. 4, n. 53455 del 15/11/2018, Rv. 274500).

Inoltre, a fronte di una condotta attiva indiziata di colpa che abbia cagionato un certo evento, occorre, poi, operare il giudizio controfattuale, ovvero chiedersi se, in caso di c.d.

comportamento alternativo lecito, l’evento che ne è derivato si sarebbe verificato ugualmente e ne rappresenti la concretizzazione del rischio.

Le argomentazioni sviluppate dai giudici di merito al riguardo sono meramente congetturali, illogiche ed inconferenti: il Tribunale di Como ha affermato testualmente che “l’imputato avrebbe dovuto…non dare la piena idoneità lavorativa, non solo perché con una patologia così grave non si comprende come possa essere idoneo al lavoro” ed inoltre “così facendo avrebbe costretto il lavoratore a intraprendere i dovuti accertamenti diagnostici” mentre la Corte di appello ha sottolineato che il giudizio di idoneità lavorativa lo avrebbe indotto a riferire alla moglie che “era tutto a posto”.

Si rammenta, inoltre, che nelle ipotesi di omicidio o di lesioni colpose in campo medico, il ragionamento contro – fattuale, condotto sulla base di una generalizzata regola di esperienza o di una legge scientifica, universale o statistica, deve essere svolto dal giudice tenendo conto della specifica attività che sia stata specificamente richiesta al sanitario (diagnostica, terapeutica, di vigilanza o di controllo) e che si assume idonea, se realizzata, a scongiurare o ritardare l’evento lesivo, come in concreto verificatosi, con altro grado di credibilità razionale (Sez. 4, n. 30649 del 13/06/2014, Rv. 262239). Sussiste, pertanto, il nesso di causalità tra la condotta omissiva tenuta dal medico e il decesso del paziente allorquando risulti accertato che la condotta doverosa avrebbe inciso positivamente sulla sopravvivenza del paziente nel senso che l’evento non si sarebbe verificato ovvero si sarebbe verificato in epoca posteriore, rallentando significativamente il decorso della malattia, o con minore intensità lesiva (Sez. 4, n. 18573 del 14/02/2013, Rv. 256338).

4. Alla stregua di quanto sopra esposto la sentenza impugnata va annullata con rinvio per nuovo esame ad altra sezione della Corte d’appello di Milano.

P.Q.M.

Annulla la sentenza impugnata e rinvia per nuovo esame ad altra sezione della Corte d’appello di Milano.

Così deciso il 21/07/2020

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    offices in droves, but quite a number have gone for the convenience and safety of working from home, with pajama
    pants on under the desk and a USB speakerphone at
    their side. In fact, it’s become very normalized for a number of jobs that rely on computers, which is
    why remote workers require proper equipment to create a functional home office environment more
    than ever. A quality supportive chair and a study standing desk
    are ideal additions to your home office, and a
    work PC or laptop are practically mandatory, but if you’re
    currently working from home, you already know you’ll need more than that for the
    sake of efficiency. And one great office addition is a high-quality
    speakerphone with sharp audio quality to help you sound more professional through those all-too-frequent .Standard
    speakerphone functionality often lacks a
    little bass, focusing instead on midrange performance (designed for voices).
    Because they don’t work like your usual portable speaker, you wouldn’t necessarily
    want to watch a movie or  with one. Still, they’re louder and sound fuller than the speakers in your phone
    or laptop, so the best speakerphone is important
    when you need wireless, amplified volume in a pinch.Read More:
     I’ve tested all of the best speakerphone
    models listed here, and given thorough reviews on the speakerphone functionality for many of them.
    Note that the ones with USB connections work with Windows PCs and Macs, whereas a
    Bluetooth speakerphone model will also work with your tablet and mobile phone.

    And most of these are compatible with the that’s essentially the industry standard.Watch this: So, keep reading if you’re looking
    to buy the best home office speakerphone for yourself
    or someone who owes you a phone call.

    David Carnoy/CNET

    I liked Beyerdynamic’s earlier Phonum speakerphone (see below), which retails for about $100.
    But the new-for-2022 Space is a slicker product and
    nice “personal” speakerphone that works well in home
    office environments. It also has more bass than the average speakerphone and
    works decently for listening to music, though it doesn’t support
    the higher-fidelity AAC and AptX codecs — only SBC. If you can afford it, you can wirelessly pair
    two of them for stereo sound. The speaker comes in a
    few different color options and has touch
    controls on the top along with LED lights that indicate whether you’re
    connected via Bluetooth, on a call and whether your microphone
    is muted. You can also connect directly to your computer with the included USB-C cable —
    the speaker charges via USB-C — and a USB-C to USB-A
    adapter is included (you can store it in a slot in the
    base of the speaker, where you’ll also find a threaded tripod mount).
    Battery life is rated at up to 20 hours, and a 10-minute charge gives you two hours of
    juice. The speaker is splash-proof and dust-resistant with an IP64 rating.Callers said I sounded clear and were generally impressed
    with how I sounded, saying they couldn’t tell I
    was on a speakerphone. Weighing 354 grams, the speakerphone is quite
    portable and a carrying pouch is included, While Beyerdynamic describes it as
    a personal speakerphone, it does have four microphones and is suitable for conference calls with up to six people sitting around
    it. While it’s a bit expensive at its $179 list price,
    I do suspect it will come down in price with time.

    David Carnoy/CNET

    The Luna is eMeet’s latest speakerphone and a good value with a list price of
    $80, though it sometimes dips to even less with an instant coupon at Amazon. It’s designed
    to compete with Anker’s PowerConf (see below).
    It’s not quite as sleek as the PowerConf, nor does it come with a protective carrying case like that model does.

    Also, its microphone performance is good but not on the level of the Jabra Speak 510
    (see below) in terms of clarity. That said, it offers good noise reduction.The speaker does
    sound clear and loud, and it’s versatile: You can go wireless over Bluetooth, plug the speaker into the USB port
    on your PC (with an included cable) or plug in the wireless dongle for a more reliable Bluetooth
    connection.It can be daisy-chained with other eMeet speakerphones to add more people — up to 12, eMeet
    says — in case you’re running a business with multiple employees from
    home or just have a really large family. 

    David Carnoy/CNET

    Anker’s PowerConf offers solid performance for the money,
    with six microphones arranged in a 360-degree array to pick
    up the voice of up to eight people in a room. This Bluetooth speakerphone charges and connects via USB-C to your computer (if you want to go the wired
    route) and easily connects to your cell phone and tablet via
    Bluetooth technology. With an integrated 6,700-mAh
    battery, you can also charge your devices with the speakerphone.
    Battery life is rated at 24 hours for call time. The speaker performed well, with good clarity and
    similar sound quality to the Jabra Speak 510.
    Jabra’s Speak 710 delivers a little fuller sound with a little more
    bass, but that speaker costs substantially more.
    While this can also be used as a speaker for listening
    to music or watching movies — and is a significant step up from the built-in speakers on your smartphone or laptop, particularly in terms
    of loudness — Anker says it’s first and foremost a conference speakerphone.
    Whether you’re in a large conference room or smaller conference rooms, it can pick up voices anywhere for
    up to eight people. A carrying case is included.Note that you can’t connect more than one Bluetooth device to this conference speaker at
    the same time. It’s also worth noting Anker also makes the newer , which is currently selling
    for . I have not tried that model but it seems very similar to this one with an updated
    design.

    David Carnoy/CNET

    The Poly Sync 20 is available with and without a Bluetooth dongle, and
    there’s also a Microsoft Teams-certified version. Additionally, there’s a to support Breast Cancer Awareness that currently costs
    without the dongle.It’s unclear if you need the dongle because the speaker
    has an integrated USB-A or -C cord to plug directly into a computer
    and charge the device, but the dongle makes for easier pairing. This has everything you want in a compact but portable speaker phone.
    Along with the USB-A connector, it has Bluetooth.
    A protective carrying case and lanyard are also included.

    There’s also a USB out port for charging a phone. Battery life is rated at up to 20 hours.Performance was solid.

    I was able to stand up to about 7 or 8 feet away from the
    speaker and callers said they could hear me clearly.
    The speaker puts out a decent amount of sound, so volume wasn’t an issue.
    It’s also worth noting that the touch button with the
    rocket icon is programmable using the Plantronics Hub
    app: You can choose between play-pause music, last-number redial and
    voice assistant as well as hold/resume call. The Microsoft Teams-certified version adds a Teams
    button next to the rocket button. That said, any model works with Teams. I played some music through the speaker and it sounds decent though not great for
    a compact Bluetooth speaker. As you might expect, it’s
    strongest in the midrange, where vocals live, so it does well with acoustic music.The Sync
    20 Plus version with a Bluetooth dongle lists for $200 but
    can be had for less. Poly also has the larger  for and the is around $450. 

    David Carnoy/CNET

    Bang & Olufsen has upgraded its dome-shaped aluminum-clad A1 speaker with improved battery life,
    better speakerphone performance (it now has a three-microphone array) and
    slightly improved sound. It’s not only the smallest wireless speaker from the Danish company, but
    also the most affordable with a list price
    of $250 (you can get certain colors for over $50
    less). While it doesn’t have the more robust speakerphone-centric
    features of other products on this list, this speaker easily sounds the best for music playback.The
    speaker drivers remain the same as those in the previous
    model, but the Qualcomm chipset that powers the speaker has been upgraded (the speaker uses Bluetooth
    5.1), bumping the sound quality up a tad, particularly at higher volumes,
    with better digital signal processing. It remains one of the best-sounding mini Bluetooth speakers,
    with richer more tonally balanced sound than other Bluetooth speakers its size — and it should sound good, considering
    its elevated price point.. It’s also worth noting that
    the A1 has multipoint Bluetooth pairing so you can connect
    this to your PC and smartphone at the same time and easily switch back and
    forth between the two if a call comes in on your phone.
    Additionally, the speaker is Alexa-enabled, meaning you can activate Amazon’s
    voice assistant by just saying “Alexa.” Battery
    life is rated at up to 18 hours at 50% volume (the earlier
    A1 didn’t live up to its battery life claims, but this number
    is more accurate) and if you can afford it, you
    can link two A1 speakers to create a stereo pair. The speaker is waterproof with an IPX 67 rating that allows it to
    be submerged briefly in shallow water.

    Get Price AlertsYou’re receiving price alerts for Bang & Olufsen Beosound A1 2nd Gen

    Jabra

    The Jabra Speak 510 wireless Bluetooth speaker, which has been out for
    a few years and is sometimes discounted to closer to $100,
    can be connected directly to a computer with a
    USB cable or wirelessly via Bluetooth. It doesn’t offer as much volume as the step up
     Bluetooth speakerphone, which costs more than twice as much.
    Jabra says the speaker is suitable for smaller
    rooms with coverage for four people in a meeting. This portable speakerphone
    has a 360-degree omnidirectional microphone and its rechargeable
    battery will last up to 15 hours of battery life in wireless mode.
    A carrying case is included.You can get this model with a UC (universal communications) USB dongle that allows you to have a direct wireless
    connection with a PC. But the wired USB option is fine, and it offers the same softphone features
    for Windows PCs or Macs.

    Get Price AlertsYou’re receiving price alerts for Jabra Speak 510

    David Carnoy/CNET

    With Jabra’s Speak 710 wireless Bluetooth speakerphone (around $205,
    you’re getting a noticeable bump up in sound and microphone quality from the Speak 510 Bluetooth speakerphone
    (it is bigger but still compact). While it costs more, if you’re looking
    for top-notch performance with excellent noise reduction in a consumer-grade
    speakerphone, the 710 delivers it. Jabra says this is rated
    for up to six people in a conference room, but you can daisy-chain a couple of
    these in a larger room to get twice the number
    of people involved. It also has an integrated USB cable for connecting directly to a computer and includes a UC (universal
    communications) USB dongle for reliable wireless connections with a Windows
    PC or Mac without installing any software (there is a ).Don’t expect it to sound great for music or movie watching,
    but it does have more bass than the Speak 510 and the
    Anker. 

    Get Price AlertsYou’re receiving price alerts for Jabra Speak
    710-UC Speakerphone

    David Carnoy/CNET

    The best things about the Cyber Acoustics
    Essential Speakerphone are that it’s compact, lightweight and simple to use.

    Callers said they could hear me clearly, and the speaker outputs a decent amount of volume for its size.
    That said, my voice didn’t sound as natural as it did with
    some of the more expensive models on this list.This is a
    fairly basic speakerphone, but it offers Bluetooth connectivity along with
    a USB wired option. It’s definitely easy to slip in a bag.
    With a list price of $70, you can sometimes find it cheaper
    with an instant coupon at Amazon. 

    David Carnoy/CNET

    Beyerdynamic’s Phonum is arguably the sleekest-looking speakerphone on this list and speakers’ voices
    come across with audio quality that sounds loud, clear and natural.
    Music performance is only OK, but it also makes for a good Bluetooth speaker for
    listening to podcasts and news reports. Compared to
    some of the other speakerphone models that cost more than $200, its feature
    set isn’t as robust and its noise-reduction doesn’t seem quite up
    to the Jabra 710’s level, but it picked up my voice well
    (Beyerdynamic says it’s equipped with its Gecko 360-degree technology
    with three modes of voice tracking) and I enjoyed using it.
    You can connect it to your computer or smartphone via Bluetooth
    or plug the speaker into your PC via USB.
    It comes with a nice carry case. 

    David Carnoy/CNET

    The eMeet M0 is a compact USB speakerphone that connects to your computer with an included USB-A to USB-C cable.

    No drivers are required — it’s plug and play — but there is no wireless option. It has a four
    smart microphone array, acoustic echo noise cancellation, noise-reduction technology and is suitable as
    a conference phone for meetings with up to four
    people. This conference speakerphone is louder and more clear than your typical laptop
    speakers and picks up your voice well from several feet away. 

    Amazon

    If you can’t afford the Jabra Speak 710 and
    are looking for a compact, more “professional” Bluetooth speakerphone, the eMeet M2 costs less than $200, has a strong feature set and performed well in my
    tests (it plays louder than you’d think for its size).
    It’s equipped with a four microphone array, acoustic echo along with noise
    reduction technology and can operate with clear sound in larger rooms with five to eight
    people participating on a conference call. You can opt to plug the speakerphone
    directly into a computer (Mac or Windows) with a USB cable or go wireless
    with the included Bluetooth USB dongle. You can also use Bluetooth connectivity for your smartphone
    or tablet. A carrying case is included.

    Sarah Tew/CNET

    The iPhone-friendly Pioneer Rayz Rally has been around for a while — I reviewed it back in 2017 —
    but it’s still being sold and is down to $70. The little personal speakerphone fits in your pocket and has an integrated Lightning cable so
    it plugs directly into your iOS device and draws power from it, though not much (it has little impact
    on battery life). Due to its size and portability, you can even use it as a car speakerphone.
    It’s not in the same class as the other speakerphones in this
    roundup in terms of sound quality or microphone performance,
    but it does give a little bump in sound quality from your smartphone’s speakers.

    The latest-generation iPhones have improved internal speakers, so the difference
    isn’t as great as it was several years ago with the
    iPhone 7 or 8, but it still has more volume (it’s all midrange, of course).The
    single button on the speaker serves as a mute button during phone
    calls (so callers can’t hear you) or a pause/play button while listening to
    music or videos. And like the  headphone, there’s a pass-through
    Lightning port integrated into the speaker that allows
    you to charge your phone with a separate Lightning cable.

    .

     

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