Sessional_Paper_1949 — Page 25

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from Mr. C. E. Terry, representing non-Chinese godown proprietors, but we consider that its introduction would add another set of regulations to a number which are already very inadequately observed. In principle it is sound, but we consider that the extension of the removal permit system, should be deferred until existing regulations are better observed and enforced, when further considerations might be given to the proposal. We recommend however that the permit system should be introduced for movement of bulk consignments of raw celluloid or cinematograph film.

Present Facilities in the Colony for Storage of Dangerous Goods and Films:

76. A particular difficulty about the observance of the Dangerous Goods Regu- lations, even were they well known to merchants and godown-keepers, is that the regulations provide for the proper segregation of goods of one category from those of another, and for separation of goods within the same category. Very few godowns exist in the Colony where such facilities are available, as they imply their splitting up into a number of comparatively small self-contained compartments. There is no proper storage for cinematograph film or celluloid in bulk, and the Fire Brigade has had to accept the expedient of insisting on storage in moored lighters in the Dangerous Goods Anchorage, or limiting storage to small quantities in enclosed compartments in places where if a fire breaks out, least damage may expect to be done, i.e., on roofs of houses, etc. It is common knowledge that the godown space of the Colony has been considerably taxed by the amount of goods to be stored, and we are aware that goods ordered in bulk for export into China in many cases have had to remain for longer periods in godowns than ever before. The pattern of the economy has changed and nobody yet knows whether the change is permanent. In these circumstances godown- keepers are unwilling to adapt their godowns or to construct new ones, especially in view of high building costs and the inadequate return from storage charges for dan- gerous goods. Storage of dangerous goods is in fact not a good commercial proposition, and godown-owners who provide such storage offer it as a port-facility and are well satisfied if they can avoid a loss. There is therefore little inducement to construct special bulk storage facilities, except for the more obvious types of dangerous com- modities, such as explosives, storage for which is provided by the Government, and petroleum products, storage of which is in special installations. Not unnaturally in these circumstances, few special storages exist.

77. These difficulties we do not feel are insuperable. At least three of the bigger European-managed godown companies provide facilities for the storage of danger- ous goods. Excluding explosives and petroleum products, the number of commodities for which special storage is prescribed is comparatively limited. For instance, almost the only requirements in respect of Category 6 goods (substances giving off a poisonous vapour) and Category 8 goods (combustible substances) is that they must be stored in bulk in premises unconnected with domestic premises. Even that requirement may be relaxed in respect of Category 8 goods with the permission of the Chief Officer of the Fire Brigade. On occasion both the Chief Officer and the Director of Marine have been prepared to relax the regulations in respect of the other categories, if they consider circumstances warrant it and there is no undue fire risk. Even though facilities for storage are limited we consider that the regulations are in general practicable and should be strictly enforced for the benefit of the public. We further consider that such enforcement should present no great hardships to owners of goods or to godown-

owners.

Classification of Dangerous Goods by Fire Insurance Companies and Their Tariff:

78. We have said earlier that the failure to observe the regulations was in our opinion principally due to ignorance, but we consider that the tariffs of the Fire Insurance Companies are a contributory cause. The basic idea of the fire insurance tariff is simple. Goods are divided into three classes, "non-hazardous”, "hazardous" and “extra-hazardous”, which classification is set out in detail in Appendix 4 together with the equivalent category of the commodity in the Dangerous Goods Regulations. We understand that this classification is basically the same as that adopted by fire insurance companies the world over, but it is simpler than that adopted in the United Kingdom. Its merit is its simplicity; its fault is that it is simplified to the extent of directing the eyes of owners of goods and owners of godowns away from the official regulations regarding the storage of goods.