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what modifications in the test are rendered necessary by the climatic conditions and that the test should be defined by the rules.

We cannot judge whether some variations in the test will be required but think it ought to be carefully determined beforehand and not left to the discretion of any Analyst on each occasion or with every variation of temperature.

With reference to Rules 6 to 18 referring to the testing of the Oil and the refusal of permission to unload or even to proceed to the wharf until the Analyst has given his certificate we beg most respectfully to point out that the loss of time involved in adherence to these rules is fearful. If the Analyst is allowed 24 hours for testing and as much more as he may think fit to take, no vessel will be able to get to the wharf under 36 hours at the best.

We submit that the time ought to be limited to 6 hours for testing and that a vessel ought to be allowed (under a penalty if the Oil turns out to be of inferior quality) to go to the wharf within 12 hours of arrival at her anchorage.

But we still urge upon the attention of the Government the propriety of dispensing with any test when a vessel is properly documented and the quality of the Oil duly certified from her loading port.

IT

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-Rule 14-

No remarks provided there is no delay for testing when certificates from the port of loading are in order.

-Rule 15-

No remarks. The words "or otherwise" might usefully be inserted after the words "by means of a supplementary valve" and "by means of a supplementary pump on shore".

-Rule 16-

After the words "for the discharge" in the second line please insert the words "or loading" to meet the needs of the traffic as explained in our preliminary remarks. This rule will have to be further modified to permit of vessels in the harbour i.e. in the usual

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