200398D TELO1 **

THE DEPARTMENT

OF TRANSPORT

J

Ms Bridget Paris

Foreign & Commonwealth Office

London

SW1A ZAH

ROOM 5/69

SUNLEY HOUSE 90 HIGH HOLBORN LONDON WCIV 6LP

TELEX

FAX No.

264084 ANSWER BACK MARBOT G

071-831 230X

4911

TELEPHONE

071-405 6911 ext 3136

GTN

3816

Your Ref:

Our Ref:

Date

5 August 1992

Dear Ms Paris

I refer to your fax of 30 July inviting my comments on Ms Barrett's use of the word "certificate" in Extension of MARPOL Annex III to Hong Kong. I comment as below.

1.

The word "certificate" in Article 5(2) obviously applies to Annexes other than Annex III. Therefore its use in relation to Annex III even in a general sense could be confusing.

2. Although Regulation 4(2) of Annex III does not specify that a signed certificate or declaration in respect of a shipment must be carried on board, it is in fact normal practice to do so.

3. However, Regulation 4(4) does seem to suggest that a special list or manifest or a detailed stowage plan is required to be carried on board. These documents provide the details of harmful substances (marine pollutants) on board.

4. Because the issue on hand is related to inspections and detention in port of ships carrying such cargoes, it is important that inspectors precisely know what document they should be asking for in order to know the details of cargo carried. Hence my suggestion is that the words

(or signed declaration)

documentation retained.

Yours sincerely

Dobfanal

D JASWAL

or manifest

OF stowage

are

200398d

II6D1E8120 WOOD

68:6

26. 9ny 9

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