4.
Document (c).
- 2
Reference......
CODE 18-77
AWO Ltd. 7/84
In
Reg. 2: There is no definition of a passenger ship. addition the term 'master of a ship' is used throughout (see my pencilled brackets on the text) in preference to the UK equivalent, 'the master'. Although the stated aim is to regulate only passenger ships, the effect of this is to bring all ships within the scope of the regulations, notwithstanding the terms of Reg. 2 (3).
T
the pura (2)(a) Reg. 3: 'deck cargo spaces' is unclear I suggest it is better to return to the UK text, cargo between deck spaces'. Delete the comma in subpara. (b). I think it is necessary to reinsert 'alternatively' between 'appropriated' and 'to the carriage' in subpara. (d), since it evokes the idea that this is space adapted to the use of either cargo or passengers, but not both, on each individual voyage.
Reg. 4: It might be desirable, subject to HK practice, to insert of these Regulations' every time there is a reference to a different regulation, as opposed to paragraph, in a particular regulation. This is a general comment which applies in all these documents
Finally, there is no penalty provision equivalent to the UK provision. This appears to be a serious omission, as we have it appears, prohibitions without sanctions,
here
5. Document (d).
Reg. 3(b): the UK equivalent is restricted to 'sea-going' vessels. This is not, however, a requirement of SOLAS, and I do not think the amendment is of great significance, but I thought it wise to point it out.
Reg. 6: Chapeau to para. 3: I do not think 'where applicable' is appropriate here.
6.
Document (e).
Reg. 3: The ships are not specified, as in the UK, to be
'seagoing ships. Again I do not think this is required by SOLAS and is a significant omission. In para. (b), however, 'Safety Convention' should be inserted between 'other' and 'ships', since I take it that it is not intended to bind non-parties to SOLAS ( and incidentally in order to give significance to the inclusion of a definition of 'Safety Convention ship' in Reg. 2).
Unless, in addition, 'waters of Hong Kong' is a term of art, it will be necessary to specify internal or territorial
waters.
Reg. 5(5): I think it would be better to change 'Where' for 'Whenever and to delete the comma after 'pilot ladder'.
1
Reg. 7(1)(a) and Reg. 11(16)(a): I suggest it would be better to retain the UK equivalent wording. The present wording envisages only one standard of material for construction of the ladder, except that the bottom four steps can be rubber. The UK text suggests one standard for the upper ladder and the same for the lower ladder
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