Sessional_Paper_1949 — Page 26

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79. The premiums charged for the insurance of goods stored in a "non- hazardous godown" are less than those charged for storage in a "hazardous godown", and so on. The insurance certificate includes a warranty that the insurance will be invalid if goods of a more hazardous nature are stored in a godown for which a less hazardous rate is charged. This therefore puts upon the godown-keeper an obligation to his customers to store only certain classes of goods. If the classification of goods corresponded more closely to that adopted in the dangerous goods regulations, it would be an invaluable adjunct to the observation of the law. "Hazardous" goods are for the most part those placed in the regulations under Category 8. “Extra-hazardous” goods include representatives from every other category of dangerous goods, but the tariff places no restriction on their storage within the same premises, while the regulations usually insist on segregated storage especially of cinematograph film. We accept the contention of the Fire Insurance Association that in the strictest sense the observance of the regulations is no concern of theirs but rests with the owners and godown- keepers, but we consider that in their own interests a realignment of their classifica- tion might be of advantage.

80. The classification above applies only to premises in non-Chinese ownership. Premises in Chinese ownership have a different tariff. The premium rate here de- pends on whether the godown is to be used for the storage of goods not excluded by a special warranty. A list of these goods is also shown in Appendix 4, and it will be seen to be a simplified combination of the "hazardous/extra-hazardous" classification used for European-owned places of storage and is referred to in the Appendix as "Chinese Hazardous". It suffers from the same shortcomings as the list of extra- hazardous goods. In addition to this simple dual classification of places of storage, there is a further classification into premises not used for domestic purposes or premises partially used for domestic purposes. The highest premium is charged for storage "without warranty" in the latter class of premises. As the storage of many of the goods excluded by the warranty in premises partially used for domestic purposes is absolutely prohibited by the Dangerous Goods Regulations, the acceptance of insurance in these cases might be construed as encouraging breaches of the law. We recommend that the Fire Insurance Association, of which we understand the vast majority of companies engaged in this class of business are members, should recommend to its members that they refuse to quote a rate of insurance for storage without warranty in premises partially used for domestic purposes. We consider that the provision of a legal requirement to this effect is not a practical proposition. We realize that refusal to grant insurance cover will not prevent storage of dangerous goods in buildings par- tially used for domestic purposes, but it would go a long way towards making it less attractive.

81. We understand that the Fire Insurance Association is now examining its dual system of tariffs for Chinese and non-Chinese owned places of storage, with a view to producing a unified tariff. We consider that this is a step in the right direc- tion, but we realize that the Insurance Association will be confronted with serious difficulties. We consider that the reintroduction of a system of rebate for safe storage might meet the desire of the Insurance Companies to preserve the higher tariff for premises under Chinese management and at the same time to quote low rates for premises which are of more elaborate construction and less subject to fire risk. Such a system might also offer an inducement to godown proprietors to adapt existing premises or construct new premises with improved anti-fire precautions.

Powers of Inspection of the Fire Brigade:

82. The Fire Brigade or the Police are authorized to search any premises which they have "reasonable grounds" for suspecting may contain something liable to seizure, which is the penalty for improper storage. It is clear that the Fire Brigade's powers of inspection are therefore somewhat limited, as it is difficult to define "reasonable grounds", though apparently an anonymous letter is regarded as such. It might be difficult to give the Fire Brigade unlimited powers of inspection by removing the "reasonable grounds" phrase, as this would allow them unreasonable powers of inter- fering with the individual. A solution recommended by the Insurance Companies and which would be welcomed by the Chief Officer would be that all godown storage whether for dangerous goods or for ordinary goods should be registered annually and