Sessional_Paper_1949 — Page 24

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or carrier in writing of the contents on delivery. The regulations prescribe that certain labels shall also be fixed on all goods of Categories 1-7, but not of Category 8. The initial onus is clearly on the owners, but if a godown-keeper has been notified of the goods and accepts them unlabelled, the onus for labelling them in our opinion then rests with him. The regulations to the Celluloid and Cinematograph Films Ordinance prescribe that receptacles for the storage of film shall be plainly marked “FILM” and celluloid waste and scrap must be stored in metal receptacles marked “CELLULOID WASTE". The use of labels is obviously designed to safeguard owners of godowns and it would be an unwise godown-keeper who did not take his own precautions for ensuring that labelling was carried out. The requirement to affix labels is of course no insurance that goods will be correctly stored, but an insistence on the use of labels would serve to bring the regulations to the attention of persons storing goods and would also assist Fire Brigade Officers on inspecting premises.

72. We consider that the labels have a useful function, but we believe that the provision of the regulations regarding labelling are almost universally disregarded, especially in respect of goods other than Categories 1 and 4. For instance, the Fire Brigade itself was unable readily to supply copies of labels. We recommend that the necessity for labelling and the places where labels may be purchased should be brought to the notice of the public, perhaps by a notice on the back of the licensing form.

73. The initial onus for labelling is placed by the Ordinance on the owner of goods, not the godown-keeper; this is as it should be. If importers could be persuaded to inform their suppliers of the procedure for labelling in Hong Kong, and we see no reason why this should not be done, it should be possible to have labels affixed at source by manufacturers or suppliers. Such a procedure would be of great advantage to shippers. If this recommendation be accepted we consider that colour-stencilling in the forms prescribed for labels should be permitted in lieu of labels. We further recommend that a similar system of marking should be introduced for packages of cinematograph film or celluloid, and that the labels should bear in Chinese characters a clear and unequivocal description of the contents.

The Use of Licence Plates for Notifying Licensed Places of Storage:

74. Licensed storage places are also required to bear a metal plate on the entrance, of a kind prescribed by the Ordinance, and given to the licensee by the Fire Brigade, on payment of a fee of $1.00. We were informed that the Fire Brigade hold no stock of these plates and have not replenished stocks since the war, and this pro- vision of the regulations has not been carried out since 1945. The use of licence plates we consider to be of value, if only because they serve to draw the attention of owners to the existence of regulations. We recommend that owners of licensed godowns should be required to display their licences in a position where they can be seen by the public. Licences should be in English and Chinese. We have some further remarks to make on the subject of licensing in a later paragraph of this Chapter, but here we wish to point out that the location of godowns, and particularly those licensed for the storage of highly inflammable goods is a factor to be borne in mind by the licensing authority, when considering the grant of a licence. It was obvious in the case of this fire, that had the wind been blowing in another direction the danger to the gasometers of the Hong Kong and China Gas Company would have been very great with a corres- ponding risk of a disaster of even greater magnitude. We feel that great care ought to be exercised in granting licences for storage in the neighbourhood of such installa- tions.

Removal Permits:

75. At present the Dangerous Goods Regulations provide that in the case of Category 1 goods (explosives) an owner must obtain a removal permit on which a fee is charged before movement is permitted from one place to another. The Chief Officer recommended to us that a removal permit should be prescribed for all categories of dangerous goods except Category 8, which would mean that a permit for removal from ship to shore would be required on the arrival of goods in the Colony. This would help him to keep track of the movement of dangerous goods within the Colony and he thought it would be administratively practicable provided that the payment of a fee, which involved an inconvenient delay, were waived. His proposal received support