Sessional_Paper_1949 — Page 23

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difficult to acquire "reasonable grounds". It is clear that if he could be notified of the arrival in the Colony of dangerous goods, his inspections (a valuable part of fire prevention) would be much less of a hit-or-miss nature and could be more fruitfully directed. There seems to be no inherent difficulty in the Marine Department notify- ing the Chief Officer of the arrival of dangerous goods and celluloid, provided that masters of ships could be made well aware of what the Colony regarded as dangerous goods, and provided that celluloid and film were added to their number. The Marine Department is not apprised of the names of the consignees, nor is it necessary that it should be, but this information can be supplied by the Imports and Exports Depart- ment should the Fire Brigade wish to trace the destination of the goods. We do not therefore consider that an amendment of the existing law is necessary, except in so far as notifying the arrival of celluloid or cinematograph film in bulk, but we recom- mend that these three Departments could with advantage work out an administrative procedure which would attain the ends of the Fire Brigade.

Licence for Possession and Storage of Dangerous Goods:

68. The licensing of premises for storage, is governed by a whole series of regulations, the most elaborate of which are concerned with substances falling within Categories 1 and 4. With regard to the latter there is a special series of detailed regulations connected with the transport by land and sea, storage in godowns, shops, garages, petrol pumps and refineries of the more unstable petroleum products. The regulations concerning the storage of the more stable substances in Category 4 (e.g. Cellulose Lacquer) are less detailed and restrictive. The regulations in respect of the storage of goods in Categories 5, 6, 7 and 8 are fairly perfunctory and unelaborate, and should not be very difficult for owners of godowns to observe. Goods of Cate- gories 5 and 6 may not be stored in domestic premises, and storage places must be licensed. There is no prohibition of storage of Category 7 goods in domestic premises, but the storage must be licensed. There is no need to have a licence to store Category 8 goods, unless the storage space is connected with domestic premises. The licensing authority is in all cases the Chief Officer of the Fire Brigade, and the onus of acquiring a licence rests primarily with the owner of the goods and secondarily with the owner of the premises in which they are stored. This means that an importer of dangerous goods should obtain a licence from the Fire Brigade, as soon as he is aware that the goods are actually en route to him. We understand from the Chief Officer that this procedure is sometimes observed by more reputable importers. Persons wishing to store raw celluloid or cinematograph film must notify the Chief Officer, who may or may not certify the storage as suitable.

69. We believe that the highly specialized requirements in respect of the storage of explosives, compressed gases, and the more unstable substances giving off inflam- mable vapour (i.e. Categories 1, 2 and 4) are probably complied with and enforced fairly rigorously by the Chief Officer of the Fire Brigade and the Director of Marine. The old regulations were largely concerned with these substances, and the new ones do not differ markedly. For these reasons and because substances of these categories were not involved in the Wing On Fire, we have excluded consideration of their storage from the scope of this Inquiry.

70. Dangerous goods may also be stored in limited quantities in shops and other similar premises, the inspection and licensing of which certainly puts a heavy burden on the Fire Brigade. The limitation of quantities adds to the complexity of the storage regulations, but while the initial fire risk in such places may be greater than in specially constructed places, the ultimate fire risk, as has been shown in the case of the Wing On Godown No. 2, is certainly greater in the latter. Again, although it is known that at the present time goods, and probably dangerous goods in some cases, are extensively stored in what in more normal times would be regarded as offices or dwelling-houses, and therefore constitute a fire risk, we do not consider that recommendations concern- ing such storage fall within our terms of reference. We have limited our inquiry to an investigation of the practice in regard to bulk storage of less obviously dan- gerous goods and celluloid in godowns only.

Marking and Labelling of Dangerous Goods and Celluloid:

The

71. The Ordinance prescribes that dangerous goods of all categories are required to be marked with the word "Dangerous" in English and Chinese characters. onus of marking the goods rests on the owner, who must notify also a warehouse-keeper