TNAG-2532-FCO40-3702-Application-of-International-Convention-for-Safe-Containers--1992 — Page 18

Anne Forryan FCO

From: A G W Stretton

SPD B1

Room 346, Baynards House

Extension 6343

Date:

15 May 1992

102 FUZ

15. 03. 22

16:26

Health & Safety Excenture

Mr Sharpe

Mr Alexander

1

International Convention for Safe Containers (CSC)

Thank you for your fax of 8.5.92 in which you ask for comments on the papers relating to extending the CSC to Hong Kong.

2

3

4

We have no objections to the proposals on health and safety grounds.

I would offer the following comments on the papers.

Paragraph 2 (A). By way of clarification of the first sentence I suggest adding a second sentence to say that approval may be by design type. Final sentence. In references to maintenance in the CSC, the "owner" may mean a lessee or bailee if, by agreement between the parties, the lessee or bailee is to assume the owner's responsibility for maintenance and examination of the container. Although interpretation of "owner" is subject to national legislation I suggest that a brief explanation of "owner" be given in this paragraph so that it is consistent with the answer to question 1 in paragraph Al (B) which refers to "owners or lessees".

5 Paragraph 3. A note of caution: the safety of everyone involved in transporting or handling containers may be affected by factors other than the structural safety of the containers, so it may be better to say that ensuring the structural safety of containers makes a major contribution to ensuring the safety of those involved in their handling and transportation.

6

I hope these comments are helpful

毗

AG W Stretton