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Name of organization/person
(Date of submission)
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Appendix
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General Remarks
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British Electrotechnical Approvals Board
22 July 1996
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1
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It would be impractical to maintain an up-to-date list of the current (safety) standards in the legislation. A general reference to the series of standards (e.g. International standards, or British standards) which would be used to establish the prescribed safety requirements would be helpful to suppliers and manufacturers, as well as to Certification Bodies.
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British Standards Institution
2 September 1996
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18
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Requests details on how British Standards Institution may apply to become recognised as a National Certification Body.
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China Light & Power Company, Limited
2 August 1996
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2
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Supports the Bill
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The Chinese Manufacturers Association of Hong Kong
19 August 1996
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3
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Supports the Bill
Manufacturers should be informed of the requirements beforehand, including their responsibilities and liabilities to offence. A reasonable grace period should be given for meeting the requirements of the regulation.
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Clipsal Asia Limited
28 August 1996
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4
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It is recommended that the regulation shall also govern the safety standard of metal or PVC conduits. Although they are not current carry products, they are insulation harness contributing to the total safety of the household electrical network.
See Tables B and C for specific comments on Clause 3 of the Bill and Schedule 1 of the Electrical Products (Safety) Regulation (the Regulation)
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Consumer Council
17 August 1996
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5
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With the advent of new technology and the proliferation of exporting countries of electrical products, a Committee on Standards should be formed to review and develop standards with outside participation.
See Tables B and C for specific comments on Clauses 9, 10 of the Bill and Part V Section 11(b) of the Regulation.
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Hong Kong & Kowloon Electrical Appliances Merchants Association Ltd
22 August 1996
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6
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See Table D for specific comments on Section 29 (1)b, Section 56 (8), Section 59 (a), (b), (c), (d), (e), (f), (g), (k), (l), (m), (n) of the Electricity Ordinance (the Ordinance).
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Hong Kong & Kowloon Electric Trade Association
24 July 1996
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7
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See Table B for specific comments on Clauses 2, 3, 6, 9, 10, 11 of the Bill.
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Hong Kong Productivity Council
13 August 1996
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8
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Supports the Bill
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Integrated Technology Company
24 August 1996
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9
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The company expresses the concern about the application of the legislation on "non-mass produced" electrical products. Since the production volume of these products is small, it would be very costly to submit each design for testing. It is proposed that the Bill should contain special provisions for this industry which is involved in non-mass produced electrical or electronic products. Specifically, it is suggested that if a system follows one of the following configurations, it should be considered inherently safe and be exempted from the safety test procedures under the Bill: (please refer to the appropriate appendix for the technical details)
(1) the system runs of an external power supply unit that has been safety-approved; or
(2) the system uses an integral pre-approved power supply unit.
|
| Tantalus Design Company 28 August 1996 | 10 | Same submission as above
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| Personal Submission - Mr K T Leong (undated) | 11 | Same submission as above
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The Hong Kong Institution of Engineers
27 August 1996
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12
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Generally supports the Bill
On the difficulty to produce a comprehensive list of standards for all household electrical products, solutions of some kind are highly recommended so that manufacturers can start planning for their design and production according to the new Bill.
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Retail Management Association Limited
23 August 1996
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13
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Generally supports the Bill
As the new legislation will affect a large range of products in the market, which will take a minimum of one year for both manufacturers and retailers to prepare for the change, the Association recommends that at least 12 months grace period should be given after the legislation has come into effect.
See Tables B, C and D for specific comments on Clause 10 of the Bill, Part I Section 3 (2) of the Regulation and Section 29 of the Ordinance
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Sharp-Roxy (Hong Kong) Ltd
12 August 1996
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14
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See Table C for specific comments on Part I Section 2 of the Regulation
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Singapore Productivity and Standards Board
6 August 1996
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15
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It is noted that Hong Kong has the Consumer Goods Safety Ordinance. Is there a Product Liability Law to impose civil liability on unsafe consumer goods?
See Table D for specific comments on Section 2 and Section 29 (2) of the Ordinance
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Underwriters Laboratories Inc.
26 August 1996
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16
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See Table C for specific comments on Part I Section 2 and Part III Sections 8(b) and 8(c) of the Regulation.
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Vocational Training Council
23 August 1996
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17
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See Table C for specific comments on Schedule 2 Item 1 of the Regulation |
