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(ii) Regulation 6 reads as follows:-
"An adequate supply of sand or dry earth shall always be kept ready for immediate use in an installation or storage shed for the purpose of extinguishing fire."
What is meant by "adequate ", and who is to judge of the adequacy, and at what intervals of time? Are there not other fire-extin- guishing substances, such as "Foamite", which ought to be taken into consideration ?
(iii) In Regulation 11, ought not "either of them" to be substituted for
them"?
(iv) Regulation 18 reads as follows:---
Each tank or group of tanks shall be surrounded by a wall or embankment of substantial construction, or shall be partially sunk in an excavation."
Are the words "substantial construction" precise enough, and who
is to be the judge of such substantiality?
Are the words "partially sunk" sufficiently precise, c.g., would a sinking of 6 inches be considered sufficient? Such a sinking would seem to comply with the strict letter of the law.
It is suggested that some words be added to Regulation 18 to ensure that the above matters be carried out subject to the satisfaction of some Government Authority.
(v) The Mixed Explosives Regulation (see Dyer Ball at pages 71 to 75)
also seems to invite some comment :—
27
(a) In the first place there seems to be no definition of “mixed explosives either in Ordinance 1 of 1873 or in those Regulations.
(b) Regulation 19 reads as follows :—
Explosives liable to deterioration shall be period- ically inspected, and any damaged material shall be at once removed from the store, and destroyed by some safe and suitable method."
What is meant by explosives "liable to deterioration"? What is meant by "periodically"? Who is to inspect? Who is to remove? Who is to destroy?
(c) Regulation 20 begins as follows :-
C
The licensee must note that lighting fires or smoking
near the store is prohibited."
The above words "must note" obviously require amend-
,,
ment, and the word near seems too vague.
VI. The Shanghai Municipal Council Regulations contains valuable suggestions. For instance, Regulation 19 (on page 14) contains a precedent which could easily be adapted for the purpose of the legislation suggested in paragraph III supra. Also it includes a provision for the putting of a storage tank or tauks on buildings exceeding 75 feet in height.
VII. Another point occurs to us, namely, that legislation appears to be required in regard to the careless storing in offices or domestic tenements of cinema-films seeing that such films are of a highly inflammable nature, as is proved by 41 (2) of the Places of Public Entertainment Regulations (see Dyer Ball at page 778) which provides that, when cinematograph displays are being given, "the films shall be rolled off metal spools, and shall be kept in metal cases, and where the light used for projecting the pictures on the screen is other than electric-light, such light shall be ignited with an electric ignition with an electric ignition apparatus."
VIII. Generally, we suggest, that legislation be passed to give the Governor in Council power to make Regulations in regard to the prevention of, escape from, and extinction of, fires.
HENRY E. POLLOCK,
R. H. KOTEWALL,
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