Sessional_Paper_1949 — Page 21

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(d) removal from storage by man-handling or road transport or lighter to

ships, trains, road transport or aircraft;

(e) departure from the Colony by ship, train, road transport or aircraft.

The problem is to ensure that dangerous goods and celluloid in bulk and in small quan- tities are handled at all stages so as to involve the minimum fire risk and danger to human life, and this is the reason for the existence of the Dangerous Goods Ordinance, 1873 with its regulations last revised in 1940, and the Celluloid and Cine- matograph Films Ordinance, 1923. It should be stated here that we did not regard our terms of reference as including consideration of the storage and handling of dangerous goods in vessels, trains or aircraft except in so far as carriage in these conveyances impinged on land storage or transport within the Colony.

62. The potency of the Dangerous Goods Ordinance rests largely in the regula- tions to the Ordinance. Broadly, the Ordinance concerns itself with the matters raised in the preceding paragraph. The regulations in use up to 1940 had dealt with explosives, highly inflammable liquids such as petrol, very strong acids, and a few substances which readily give off an inflammable vapour. We formed the impression that these older regulations were well known, and possibly well observed. In 1940, there was a drastic revision of the régulations, the exact reason for which we were unable to ascertain. These new regulations are not at all well known to the general public, and the reasons possibly are as follows:

(1) they were made in 1940, a period of great stress;

(2) a very considerable latitude was as usual permitted administratively in their observance during the initial twelve months of operation, and the war intervened before there was a tightening up on enforcement;

(3) they were not readily available in published form till about the middle of 1948, and they were not in any case available in Chinese transla- tion;

(4) both the Fire Brigade and commercial concerns generally with the pos- sible exception of some of the larger godown companies have been so busy since 1946 in reinstating their 1939 standards and dealing with an unprecedented volume of work that they have had little time to attend to anything but the barest essentials, among which they have not included the strict observance of the dangerous goods regulations.

We think that the disregard of the regulations has been a result of ignorance rather than deliberate intention.

63. When we commenced our deliberations, the current impression was that the regulations for the storage of dangerous goods were excessively complicated and in any case impracticable. There are some further observations on their practicality in a later paragraph, but here it is only necessary to say that whatever their merits or demerits, the 1940 regulations have never been given a chance to be applied in a practical manner during a period of normality, and their virtues and shortcomings therefore remain largely unascertained. At first sight they appear voluminous and complex, but the principles are simple enough. There would seem to be no difficulty in godown owners at least being familiar with their requirements. We understand that in England there are two separate sets of regulations, one for the carriage of goods at sea, and one for storage on land; and neither are at present considered satisfactory. It is under- standable that, given the specialized economy of Hong Kong, the framers of the local regulations tried to combine regulations for carriage at sea and storage on land in one Ordinance. One difficulty is that there is no international agreement on the subject of what constitutes dangerous goods. There is a Committee at present sitting in the United Kingdom on this very subject—it is specially concerned with the shipping aspect and we understand that it proposes a modification of classification though not a radical one. These developments are being closely followed by the Marine Department.

64. In Hong Kong dangerous goods are divided into 8 Categories, as follows:

1. Authorized explosives, which include ammunition and fireworks;