CO129-626-2 Movement of dangerous goods around Hong Kong 1-1-1951 - 30-4-1951 — Page 28

17

27

31.

Wording and Lay-out of Draft Regulations attached

While we are well aware that the Regulations we now submit are in draft form only, we would like to emphasise that in their final fairing the exact meaning now given should be rigidly retained and, as far as possible, legal complexities in phrasing be avoided.

We recognise that these Regulations require to be put into legal form, but the essence of this requirement should not be obscured by legal phraseology. We recommend also that the Regulations should be printed both in English and in Chinese, despite the difficulty of translation into Chinese of many technical terms.

Comprehensive indexes are now in course or preparation, but it was not considered desirable to delay the presentation of this Report for their completion.

The Sub-Committee on Shipping, having in mind the efficacy of lightly humourous illustrations during the last war in the format of Convoy Instructions, Signalling Manuals, etc., used and understood by the crews of ships of many nations, have submitted some such illus- trations and recommended their inclusion in the Regulations. The Committee as a whole realises the value of "visual aids" and, if there were a "Fougasse" among us, would not hesitate to endorse this recom- mendation. We forward with this Report the several illustrations submitted and recommend that their use as posters be considered by Government.

We recommend also, for ease in amendment, that the Regulations and Appendices be published in loose-leaf, form and in separate sections.

32.

Implementation of our Recommendations

The Committee has devoted a considerable time to the formation of these new Regulations, but obviously they will have little value unless provision is made to secure their enforcement. No casual force of watchmen or guards would be satisfactory for this purpose.

The legal responsibility for the safe handling of Dangerous Goods on board a ship or vessel devolves on the master and he should be encouraged to report godown operators, stevedores and their workmen found breaking the Fort safety regulations in these operations. Breaches of safety regulations on board lighters or other vessels used in the movement of Dangerous Goods must be charged against the lighter- men and/or stevedores involved. Where, under these proposals, it is not practical or possible to pin the responsibility for the offence on either godown operators or lightermen, the prosecution of the individual offender shall be a competent act. It is essential for proper handling in moving and stowing these commodities that breaches of the Regulations committed by any person should be forcibly brought home against the offenders.

The bonding of stevedores and lighterage companies handling Dangerous Goods should in itself be a useful control. As a corollary, it is considered that elementary instruction on the proper safety pre- cautions to be observed should be given to these stevedores and their workmen.

The responsibility for maintaining an adequate and res- ponsible watch on board a ship and in the holds while Dangerous Goods are being loaded or discharged, or in a hold in which Dangerous Goods are in transit, is obviously the master's. There must, in addition, be a general over-all technical supervision to ensure a reasonable

/ degree