The Rules for life-saving appliances include the Merchant Shipping (Life-Saving Appliances) Rules 1965 and the Merchant Shipping (Fire Appliances) Rules 1965.
Although by virtue of the Merchant Shipping Safety Convention (Hong Kong) No.1 Order 1953 the Governor has the same power as the Secretary of State to exempt any ships or classes of ships from any requirements of the Rules for life-saving appliances, there does not seem to be any suggestion on the part of the Hong Kong Marine Department for any reduc- tion in the rule requirements for safety equipment on the ships in question. Provided this is so there seems to be nothing of concern to
us.
7 So far as acceptance of particular items of equipment are concerned
this is a matter for the Hong Kong Government as at present and it is for them to decide whether the equipment meets the rule requirements. We do not seek to control this aspect here and it is probably inevi- table that they would be more likely to find Japanese equipment accept- able than we have reason to do. The procedure under (a), (b) and (c) of the 15th paragraph of the Director of Marine's letter of 5 May seems unobjectionable. Though we may perhaps be rather less flexible than Hong Kong, we adopt the same sort of line and do not necessarily insist on replacement of "non-approved" equipment on ships being transferred to UK registry.
RADIO EQUIPMENT
The requirements in this respect are laid down by the International Convention for the Safety of Life at Sea 1960 and would have to be met in any country which is party to the Convention. The standards set in the United Kingdom Radio Rules are somewhat more demanding, and they apply only to ships registered in the UK. As long as the ships conform to Convention standards we would have no objections.
I hope you will find the above information helpful.
Yours sincerely
W J Madigan