on 15 December 1998
Panels of Environmental Affairs and Transport
A Proposal to Introduce LPG Taxis - A Consultation Paper
Members requested at the Joint Panel meeting held on 27 November 1998 for a written response from the Administration to the submissions made by a deputation and the following issues raised at the meeting for further discussion:
The Deputation's Views and the Administration's Responses
- the provision of vehicle workshop and mechanics for servicing LPG taxis;
- the safety requirements for a vehicle workshop for LPG taxis;
- training to equip taxi drivers with the necessary skills to undertake maintenance works for LPG taxis themselves; and
- improving driving skill to reduce the level of smoke emissions.
2. Two written submissions were made by the deputation at the meeting on 27 November 1998. Our specific responses are set out in Annex 1 and 2.
LPG Vehicle Workshop and Safety Requirements
3. The repair and maintenance of those parts related to the fuel system of an LPG vehicle must be undertaken at authorised workshops which are classified as notifiable gas installation under the Gas Safety Ordinance, Chapter 51. Construction and use of these workshops require approval from the Gas Authority (i.e. the Director of Electrical and Mechanical Services) to ensure gas safety during repair and maintenance of the LPG fuel system on an LPG taxi.
4. The Electrical and Mechanical Services Department (EMSD) has already prepared preliminary guidelines on the safety requirements for an LPG vehicle workshop. A copy of the requirements is at Annex 3. The basic requirements are good ventilation (usually by mechanical means) and provision of a gas detection system as a safety precaution. These requirements are not technically difficult to comply with.
5. Efforts are being made to explain the requirements to the trade. In addition to briefing those members of the trade who have approached us for further information, the EMSD has recently briefed a vehicle repair trade association which is said to represent over 70% of the stakeholders in the taxi repair industry.
6. So far, over 90 vehicle workshops have expressed interests in equipping themselves for servicing LPG taxis. More parties are expected to be interested in setting up workshops for maintaining LPG vehicles when the fleet of LPG taxis grows.
7. Among the 90 vehicle workshops, 40 of them have been inspected. 11 vehicle workshops have been found suitable for servicing LPG vehicle if proper safety measures are put in.
8. To serve the whole fleet of 18,000 LPG taxis, around 60 LPG vehicle workshops of various sizes (equivalent to around 400 maintenance bays) would be required, taking into account that the repair and maintenance of parts unrelated to the fuel system of an LPG vehicle could be undertaken by regular vehicle workshops. The Administration will closely monitor the development in this respect and will take all necessary measures to help ensure that sufficient LPG vehicle workshops can be set up.
LPG Vehicle Mechanics
9. Under the Gas Safety Ordinance, only a competent person who has received proper training and has substantial practical experience can carry out work on or in relation to a gas pipe. The Vocational Training Council is organising free training courses on a part-time basis to provide in-service motor mechanics with the additional training needed to become competent persons for servicing LPG vehicles.
10. The first course for the motor mechanics started on 29 October 98. The original plan of the Vocational Training Council (VTC) was to train 100 mechanics per year. In response to the large number of applications to attend the course, VTC will increase the number of part-time training courses by 50% and incorporate LPG vehicle training in the syllabus of their existing full-time courses. Thus, we estimate that at least 150 LPG motor mechanics can be trained per year.
11. To serve the entire fleet of 18,000 taxis, about 500 LPG motor mechanics would be sufficient. The current arrangement should be able to train sufficient LPG vehicle mechanics to keep pace with the vehicle servicing needs of LPG taxis.
12. It is not necessary for drivers of LPG taxis to undergo special training for the operation of such vehicles since they are constructed to be user friendly and operate in very similar manner as diesel taxis. To enable the public, including the drivers of LPG taxis, to gain proper understanding of LPG vehicles, the Electrical and Mechanical Services Department is now preparing an information pamphlet which will be circulated to members of the trade and the public.
13. If taxi drivers or any other persons wish to carry out maintenance works on the LPG fuel system of the taxis, they have to undertake the training course organized by VTC to acquire the necessary knowledge and skill for gas safety reasons. This, apart from being a statutory requirement, is also essential to achieving the highest safety standards for maintaining LPG vehicles.
Driving Skill and Smoke Emissions
14. A major cause leading to large number of smoky vehicles is the lack of proper maintenance. To address this, an extensive education campaign is being conducted. The Environmental Protection Department has prepared a leaflet providing full range of tips for preventing excessive smoke emissions, one of which is on driving skill. This leaflet has been attached to every emission testing notice we send out. The department is also seeking a wider circulation of this leaflet through the transport associations. A copy of the leaflet is attached at Annex 4 for Members' information. This education programme is being backed up by stronger enforcement action against smoky vehicles and by the introduction of better testing equipment that will expose failure to maintain vehicles properly.
Planning, Environment and Lands Bureau
Responses to the Written Submission from Dr. Gordon S. Maxwell
Dr. Maxwell considered that the following could help introduce LPG taxis to Hong Kong on a large scale:
(a) Financial incentives
- Financial incentives should be provided to assist the introduction of LPG taxis.
- The Government should provide interest-free loan to taxi company to introduce new LPG taxis in 1999.
(b) Training on vehicle maintenance
- LPG training courses should be provided free of charge to the vehicle mechanics to preclude any excuse for not taking the course.
- LPG the Hong Kong Way - a scheme for all, not just taxis: this may take the burden and focus out of taxis and place the responsibilities and opportunities of urban air quality enhancement on the shoulders of all car owning citizens.
- Start an LPG trend, e.g. a top person or a movie star "runs on LPG". This might get over the false idea that LPG is a "slow fuel" compared to petrol.
- Make taxi drivers and their company managers who convert to LPG "Heroes of Hong Kong".
- Link the LPG scheme to tourism as a sort of brave new Hong Kong running clean in 1999.
He also believed that the following factors also contribute to excessive emissions from diesel vehicles:
- low quality diesel fuel
- poorly maintained and serviced vehicles
- sub-standard or inappropriate driving practice.
(a) Introducing LPG taxis
- We would like to thank Dr. Maxwell for his suggestions to help introduce LPG taxis to Hong Kong on a large scale.
- We shall consider his views on providing financial incentives along with all the other feedback provided during the consultation exercise.
- The Vocational Training Council has already started the first course for training in-service vehicle mechanics to service LPG vehicles. The course is free of charge to its students. Their original plan was to train up to 100 vehicle mechanics per year, but in response to the very strong demand, they will increase the number of part-time training courses by 50%. To ensure adequate provision of mechanics to service LPG taxis in the long term, they will incorporate LPG vehicle training in the syllabus of their existing full-time courses.
- As explained in our previous response, our current air pollution problem with respirable suspended particulates and nitrogen oxides mainly comes from diesel vehicles. Using LPG vehicles to replace petrol vehicles will not help solve the air pollution problems in Hong Kong. Our target is therefore diesel vehicles and introducing LPG taxi is the first step. We wish to thank Dr. Maxwell for his publicity proposals and will take them into account when promoting LPG vehicles.
(b) Excessive Emissions from Diesel Vehicles
- The requirements for the quality of motor diesel in Hong Kong are as stringent as those of the European Union and are at a leading position in Asia. Both the diesel fuel quality and diesel vehicle emission standards in Hong Kong are better than those in New Zealand. In addition, the Customs and Excise Department has already intensified their effort in stamping out the use of illegal diesel.
- To raise the maintenance standards of diesel vehicles, we are now introducing an advanced smoke test, which is done with the aid of a chassis dynamometer. Although the current smoke test is widely used in many developed countries, the more advanced test will be more effective. After introducing this new technology, Hong Kong will become one of the few places in the world using dynamometers for routine enforcement purpose to control vehicle smoke. In addition, we are also considering increasing the fixed penalty fine for smoky vehicles to enhance the deterrent effect and to ensure vehicle drivers pay more attention to proper preventive maintenance.
Responses to the Written Submission from
The Urban Taxi Associations Joint Committee
The Committee fully supported the Administration's effort in improving the air quality. However, the economic slump had made it difficult for the taxi trade to switch to LPG within a fixed period. As such, the Committee had the following suggestions:
- Diesel taxis should be allowed to use up to the end of their service life.
- The Administration should provide financial incentives, interest-free loan or free LPG taxis if all diesel taxis had to be phased out within a fixed period.
- To avoid the impression of forcing the taxi trade to use LPG, the Administration should not increase the fixed penalty fine against smoky diesel taxis before LPG becomes the mandatory fuel for taxis.
In our current proposal, in-service diesel taxis will be allowed to be used to the end of their service life. As a matter of course, however, it is desirable to see all diesel taxis to be replaced by LPG taxis quickly. We shall take into account of all the feedback from the consultation and will work out appropriate measures including financial incentives, if necessary, to encourage all diesel taxis to be replaced by LPG taxis by the end of 2005.
Our proposal to increase fixed penalty fine against smoky vehicles is part of our comprehensive efforts to reduce vehicle air pollution. It is not aimed at forcing the taxi trade to switch to LPG taxis but rather to encourage vehicle owners to maintain engines properly so as to avoid smoke. We will consult all relevant parties when we have worked out the proposal to increase the fixed penalty fine against smoky vehicles. The views of the Association will be given due consideration along with any other feedback during the course of that consultation exercise.
Preliminary Gas Safety Requirements for LPG Vehicle Workshop
1. Statutory Requirements
1.1 An LPG vehicle workshop is classified as a Notifiable Gas Installation and regulated under the Gas Safety Ordinance, Cap 51. As such, the owner of an LPG vehicle workshop is required to apply for construction and use approval from the Gas Authority (i.e. the Director of Electrical and Mechanical Services) for compliance with the necessary safety and ventilation requirements.
1.2 The owner of an LPG vehicle workshop has a responsibility to ensure that the workshop and the equipment therein are operated and maintained in a safe manner, and has adequate number of competent persons to carry out repair and maintenance work of LPG vehicles. Motor mechanics, who have successfully completed LPG vehicle training courses, would be assessed by the Gas Authority for enlisting as competent persons.
This document sets out the gas safety requirements of facilities and precautions for an LPG vehicle workshop including any work on LPG vehicles carried out in the workshop.
3.1 An LPG vehicle workshop shall be readily accessible in a well-ventilated area at ground level, and never below cellars or in basements. A workshop located at upper floors may be considered under special circumstances with a well ventilated access road.
3.2 An LPG vehicle workshop should not be located in the same building as residential accommodation, unless it is well ventilated and under special circumstances.
3.3 Drains or unventilated pits shall be avoided in the workshop floor area or in the immediate vicinity of the workshop. Where a gully or drain is unavoidable, the opening shall either be securely covered or the drain suitably sealed.
3.4 Adequate area shall be provided for repairing and maintenance of LPG vehicles. The perimeter of the workshop area shall be marked conspicuously on the ground.
3.5 Warning signs showing "LPG Vehicle Workshop/石油氣車維修工場" and "No Smoking/不准吸煙" shall be prominently displayed at the workshop area.
4.1.1 The design of an LPG vehicle workshop shall be such that occurrence of a build-up of an LPG/air mixture above the lower flammable limit is minimised by provision of adequate ventilation.
4.1.2 Wherever possible, adequate natural ventilation should be provided, but where adequate natural ventilation is unattainable, mechanical ventilation shall be provided as an alternative.
4.1.3 An LPG vehicle workshop shall be ventilated utilising air inlets and outlets arranged to provide air movement across the floor as uniformly as practicable and in accordance with Sections 4.2 and 4.3.
4.1.4 Ventilation apertures and/or ducts shall be positioned in such a way so as to prevent accumulation of LPG.
4.2 Natural Ventilation
4.2.1 Apertures for natural ventilation shall be situated in external walls of an LPG vehicle workshop such that :-
- the bottoms of low level ventilation apertures are not more that 150 mm above the floor;
- the tops of high level ventilation apertures are not more than 500 mm below the ceiling;
- the effective low level ventilation area is within 500 mm from the floor; and
- the effective high level ventilation area is within 1000 mm from the ceiling.
4.2.2 Ventilation apertures shall be provided with a total effective area of at least 0.03 m2 per m2 of floor area at low level and 0.015 m2 per m2 of floor area at high level.
4.2.3 Ventilation apertures shall be at least 1 m from openings into other buildings or any fixed source of ignition.
4.3 Mechanical Ventilation
4.3.1 A minimum ventilation capacity of 500 litre/s per vehicle shall be provided for mechanical ventilation systems in the workshop area.
4.3.2 The airflow velocity within any exhaust duct of the ventilation system shall not be less than 5 m/s.
4.3.3 The inlet apertures of the ventilation duct system shall be located at not more than 150 mm above the floor level.
4.3.4 The outlet of the ventilation system shall discharge at least 1.5 m away from any opening into the workshop, adjacent buildings, or any fixed source of ignition.
4.3.5 A clearance of 150 mm shall be maintained around the air intakes of the ventilation system to prevent blockage of the inlet openings.
4.3.6 All electrical apparatus for a mechanical ventilation system shall be of a flameproof type and be suitable for use in Zone 1 hazardous areas in compliance with BS 5345 or equivalent.
4.3.7 An audio and visual alarm system indicating failure of the mechanical ventilation system such as interruption of electrical supply, failure of extraction fan, etc. shall be provided for the system. Emergency procedures in response to the alarm shall be prominently displayed in the workshop area.
4.3.8 The ventilation system shall be started before the work commences and be kept operating whilst the work is in progress.
5. Gas Detection System
5.1 Gas detectors shall be calibrated for detection of LPG and be located at not more than 150 mm above the floor level around the workshop.
5.2 A gas detection system shall provide an audible and visual alarm, if there is a flammable gas mixture with concentration reaching 20% of the lower flammable limit.
5.3 The detection system shall be capable of activating the mechanical ventilation system if the system is not switched on.
6. Fire Protection
6.1 At least 2 fire extinguishers of dry powder type shall be provided at the workshop.
6.2 Other fire services requirements shall be adhered to as may be stipulated by the Director of Fire Services.
7. Safety Precautions
7.1 Inside the workshop, unless a vehicle has been tested and a leak-free condition has been verified:-
- the space in the vicinity of 3 m from the perimeter of the vehicle to a height of 1 m above the highest point of the LPG fuel system should be classified as Zone 1;
- ignition sources shall be kept out of the hazardous zone; and
- the gas outlet valve of the LPG cylinder shall be closed at all times, except when checking or testing is being carried out which requires the gas.
7.3 All electrical installations or appliances for use in Zone 1 area shall be of flameproof type in compliance with BS 5345 or equivalent.
7.4 No smoking is allowed in the workshop area.
7.5 Portable combustible gas detectors shall be kept readily available for gas leak detection.