August 28, 1996
Our Ref.: CL96/MD/067
By fax & post
Legislative Council Building
8 Jackson Road
Attn.: Ms. Estella Chan
Dear Ms. Chan,
Re.: Electricity (Amendment) Bill 1996
We refer to your letter ref. CB1/BC/29/95 regarding the captioned and we wish that you could accept this late submission of comments of which we required reasonable time to collect from our manufacturing bases located in Australia, PRC and other Asian countries.
On behalf of Clipsal Asia Limited, I am writing comments to the proposed Electricity Bill as follows:
1. In Clause 3 (b), the exemption for electrical products intended for use outside Hong Kong will be removed.
Removal of this exemption will induce great inconvenience to overseas visitors, students going to study aboard, emigrants, contract expatriate workers and frequent travellers etc. Foreseeable loss in the travel related businesses in Hong Kong will also be resulted. We strongly recommend to retain the exemption provided that the concerned electrical products shall be explicitly labelled for use outside Hong Kong. Or even more effective, the prices of the concerned electrical products shall be listed in overseas currency e.g. U.S. dollars in all retail outlets to identify in the first place that they are intended for use overseas.
2. In the General Conditions of the SCHEDULE 1 - ESSENTIAL SAFETY REQUIREMENTS FOR ELECTRICAL PRODUCTS, there is no specific safety standard of which the manufacturers and/or the suppliers of electrical products shall refer to. We recommend that compliance with the IEC Standard or equivalent should be employed extensively throughout the paper. As the trend indicates, IEC Standard will be the ultimate and the only standard recognised all over the world in the future. At the moment, most of the industrial developed countries accept both the IEC Standard and the standards of their own countries e.g. U.K., Germany, France, P.R.C., Australia etc. simultaneously. In Hong Kong, for instance, most of the electrical consulting engineers even Hong Kong Housing Authority accept both the IEC Standard and the British Standard for electrical installation products in new building projects. In the meantime, the International Electrotechnical Commission is also undergoing harmonisation programme with the standards of the rest countries for example the South African Bureau of Standards (SABS). Increasing number of such harmonisation programme will be realised in the near future. By adapting to the IEC standards, we could set up a base line for the least electrical safety standard and the compatibility of electrical safety for products intended use in Hong Kong. This would also save a lot of resources in assessment of a standard not yet recognised by the Director of EMSD and greatly reduce the foreseeable disputes in safety compliance in the future.
3. Clause 2 (c) of the SCHEDULE 1 reads persons, animals and property are adequately protected against any non-electrical danger which might be caused by the electrical product. In our opinion, this clause should be deleted because "any non-electrical danger" could mean "every possible danger". It will be absolutely absurd that a manufacturer of electrical product may be accused for non-compliance with the regulation if someone drops the electrical product onto another person causing physical injury or other harm.
4. Clause 2 (e) of the SCHEDULE 1 reads the insulation is suitable for all foreseeable conditions. Again, this sentence is so arbitrary that "all foreseeable conditions" will include for instance cutting by knife literally. We suggest to change the sentence to " the insulation is suitable for preventing electrocution (or electrical shock) under normal operation conditions.
5. For the same token, the word "any" should be deleted in all the clauses stipulated to 3. Protection against hazards which may be caused by external influences on an electrical product and "under normal operation conditions" should entail the said clauses.
6. Metal or PVC conduits are not mentioned in the entire paper. Although they are not current carrying products, they are insulation harness contributing to the total safety of the household electrical network. Accordingly, we do recommend that the regulations shall also govern the safety standard of metal or PVC conduits.
For and on behalf of
CLIPSAL ASIA LIMITED
c.c. Parklin Ho / P. K. So - Clipsal Asia Limited
Last Updated on 10 December 1998