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Notes of the 5th
BLG meeting – Theme Park
1
Notes of the 5th
Meeting of
Business Liaison Group (theme park)
Date & time : 9:30 am on 11 Jun 2008 (Wed)
Venue : Rm 601 Conference Room, West Wing, CGO
Trade representatives:
Hong Kong International Theme Parks Limited
Mr Tommy FUNG
Manager
Ocean Park Corporation
Mr Joseph LEUNG
Mr Alan CHAN
Executive Director, Revenue
Executive Director, Operations
Kai Shing Management Services Limited
Ms Karen TUNG
Assistant Property Officer
Hong Kong General Chamber of Commerce
Ms Charlotte CHOW
Senior Manager
Government representatives:
Economic Analysis and Business Facilitation Unit (EABFU)
Mr WC CHAN (Chairman)
Mrs Yvonne FONG
Miss Ryre TAM
Ms Florrie AU-YEUNG
Home Affairs Bureau (HAB)
Miss Ellen CHAN
Head, Business Facilitation Division
Chief Management Services Officer
Management Services Officer
Project Officer
Assistant Secretary
Food and Environmental Hygiene Department (FEHD)
Ms Kitty CHEUNG
Superintendent (Licensing)
Buildings Department (BD)
Mr Chi-kuen CHEUNG
Miss Alice NG
Mr Y Y LI
Chief Building Surveyor
Senior Building Surveyor
Senior Building Surveyor
Electrical and Mechanical Services Department (EMSD)
Mr Andrew YAN
Mr Leakey LAU
Senior Electrical & Mechanical Engineer
Electrical & Mechanical Engineer
Fire Services Department (FSD)
Mr Tony YIP Senior Divisional Officer
Mr C F HUNG Assistant Divisional Officer
Television and Entertainment Licensing Authority (TELA)
Mr Alan TANG
Mr Joe LEE
Senior Licensing Officer
Senior Licensing Officer
Notes of the 5th
BLG meeting – Theme Park
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Action
Introduction
1. The Chairman welcomed both the trade and Government representatives to the
meeting.
Agenda 1 – Confirmation of notes of the last meeting
2. The notes of the last meeting were confirmed without amendment.
Agenda 2 – Presentation: proposed changes in sanitary fitments provisions in Places
of Public Entertainment (PPE)
3. BD staged a presentation and briefed the trade on the background, the purpose and
the proposed changes and clarified the following points :
(a) the proposed standard would increase the number of sanitary fitments for female
in places of public entertainment;
(b) the changes required legislative amendments to the relevant regulations, which
were aimed to submit to Legislative Council in legislative year 2008-09;
(c) the new standard would not carry retrospective effect;
(d) the new standard would apply to building plans to be submitted after the
enactment of revised regulations; and
(e) for partial alteration in a theme park, the new standard would only be applied to
the area affected by the alteration.
The presentation pack is at Annex 1. The trade was welcome to forward their
comments on the proposed changes to BD in 2 week’s time.
4. In 85% of time, the patronage of theme parks did not reach the full capacity. At
present, the existing provision of sanitary fitments for theme parks was derived
from the average number of visitors. The operators asked if BD would allow any
discount factor for “maximum capacity of a theme park prescribed by the licensing
authority” in specifying the provision of sanitary fitments.
5. BD appreciated the special operational environment of theme parks and explained
that the existing regulation only stipulated the minimum requirement and did not
provide for any discounting factor. In view of the special situations in theme
parks, BD encouraged the applicants to make use of the pre-submission enquiry
service for discussion on such requirements. Moreover, applicants could provide
All
Notes of the 5th
BLG meeting – Theme Park
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Action
information to support any alternative proposals for BD’s consideration.
6. EABFU asked if the maximum capacity of a theme park approved by FEHD in a
PPEL would tally with that of BD. BD explained that FEHD stipulated the
maximum capacity of a PPE according to BD’s advice.
7. FEHD added that the requirement for provision of sanitary fitments in a theme
park would depend on the “maximum admission capacity” proposed by the
applicant; and in accordance with Reg. 5 & 7 of the Building (Standards of
Sanitary Fitments, Plumbing, Drainage Works and Latrines) Regulations, Cap.
123I.
Agenda 3– Matters arising
Duplicated requirements for maintenance records of amusement rides
8. FEHD would lift the duplicated requirements and update the Application Guide
accordingly.
FEHD
Exemption of small marquees from certification of structural safety
9. BD would adhere to the 3-tier system for certification of building safety. A
blanket exemption for all marquees was infeasible. The trade could apply for “type
approval” of standard marquees in advance so that the processing of temporary
PPEL applications could be speeded up and the related certification costs could be
minimised. For small rain shelters, the trade could obtain “type approval” so that
they could set up the shelters anytime anywhere in theme parks when necessary.
Provision of guidelines / specifications on safety requirements of common temporary
structures
10. BD would insert the existing guidelines / technical specifications related to
commonly used temporary structures, inflatable games and kiddie rides into the
Application Guide and FEHD would update the Application Guide accordingly.
BD
FEHD
Separate forum for discussion of safety requirements listed in the Application Guide
11. Chairman reckoned that the BLG meetings had already been a regular and
Notes of the 5th
BLG meeting – Theme Park
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Action
convenient forum for discussion of the contents of Application Guide. Where
necessary, operators could invite their authorised persons or contractors to attend
the BLG meetings.
12. In the past, upon the request of the organisers of large events, BD had conducted
briefing sessions on licensing process and requirements of PPE Licence. The
department would also organize similar briefings should the situation warranted.
Performance pledge for approving alteration works in PPE
13. FEHD reported that Efficiency Unit (EU) was reviewing the approval process for
alteration works in premises running food business. The FEHD would explore the
feasibility of applying the recommendations in the context of PPE licensing.
FEHD
Suspension and resumption of food business
14. A theme park operator had been warned by a health inspector about the possibility
of cancellation of food business licence for continuous suspension of food
business.
15. FEHD explained that if a health inspector identified any voluntary suspension of
food business he would record the case. He would also ask if the licensee had
any intention to resume the business; otherwise the licence might be cancelled
under legislation. In response to the enquiry at the BLG meeting, FEHD
confirmed that demerit points would not be deducted due to temporary suspension
of business.
16. In response to an enquiry, FEHD further clarified that a suspended food business
could resume operations anytime without prior approval from FEHD. Upon
resumption of food business, a site inspection would be arranged.
Use of food carts certified by the Food and Drug Authority (FDA) of the US
17. Park operators mentioned the food carts approved by the FDA, in the context of
food hygiene, for preparation of food for mobile hawking and requested FEHD to
consider approving the operation of these food carts within park areas. One of the
operators invited FEHD to visit the theme park to better understand the mechanism
and the operations of food carts. FEHD was considering the suggestion.
FEHD
Notes of the 5th
BLG meeting – Theme Park
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Action
Pooling of Hygiene Manager / Hygiene Supervisor (HM/HS)
18. FEHD stated that the purpose of designating full-time HM/HS to individual
licensed food premises was to strengthen food safety through direct supervision of
HM/HS. The proposed pooling of HM/HS would defeat the purpose. A health
inspector would record any temporarily absence of HM/HS identified during
inspections and take follow-up actions. No penalty would be imposed for
occasional absence with reasons acceptable to FEHD. Besides, a licensee would be
required to produce the course certificates of the appointed HM/HS and the
notification of changes during FEHD’s inspection.
19. The trade opined that the HM/HS system might be useful to small and medium
food businesses. In the case of theme park where food hygiene was centrally
monitored by an independent quality control unit according to international food
hygiene standard, the existing HM/HS system hampered the operations and
increased their administrative burden. The trade wished FEHD to take into
account the unique operations of food business in theme parks and the international
standard adopted by their independent quality control unit; and adopt a more
flexible approach to achieve the system objectives.
20. Regarding the flexibility, BD referred to the open kitchens at fast food chain stores.
Instead of the prescriptive fire safety requirements which required full partition
between the dinning area and kitchen, BD accepted the fire engineering approach
which allowed the layout of open kitchens.
21. Chairman advised that to facilitate FEHD considering the suggestion, the trade
should provide the department with more details of the independent quality control
system. EABFU would be happy to make necessary co-ordination.
22. FEHD welcomed the centralised food control system adopted by trade. However,
the existing HM/HS system was licence-based. FEHD would further improve the
notification system for reporting changes of HM/HS through electronic means.
FEHD
Trade
Notification of change of HM/HS
23. FEHD said that the e-notification of change of HM/HS could be implemented in a
few months. Details would be given at the BLG meetings.
FEHD
Notes of the 5th
BLG meeting – Theme Park
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Action
Issue of amusement with prize licence (AWPL) without waiting for issue of the
temporary PPE)
24. TELA said that each AWPL would be accompanied by an “approved game list” and
the respective PPEL. If the licensee wanted to conduct additional AWP for
ad-hoc events in the licensed premises, approval should be sought from (i) TELA
for a new AWPL covering the additional games and (ii) FEHD for a temporary
PPEL.
25. TELA could issue an AWPL upon the issue of temporary PPEL by FEHD. If the
additional games were approved ones, TELA advised the trade to consider
adopting the “Game Zone approach” and “Notification System for changes of
approved AWP” which would expedite the approval process and resulted in early
launch of additional games.
Increase in the cost of participation in each AWP
26. An operator reflected their customers’ requests for better quality of prizes.
Accordingly, the cost of playing each game needed to be raised.
27. HAB said that the matter would be considered when the Gambling Ordinance was
due for a review.
HAB
Urgent processing of permit for amusement rides
28. To facilitate the launch of amusement rides on weekends, Sundays and public
holidays, EMSD would make special arrangement for compliance inspections
provided that theme park operators could inform the department of their detailed
plan well in advance.
Introduction of Multi-year PPEL, Provisional PPEL & Extension of validity of
Temporary PPEL ( involving temporary structures )
29. The HAB had commenced the preparatory work for legislative amendments. The
trade would be consulted in due course.
HAB
Notes of the 5th
BLG meeting – Theme Park
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Action
Applications from the same park handled by two different offices of FEHD
30. In a recent meeting with the park operator, FEHD explained about the division of
work by geographical boundaries of district offices. FEHD had reminded staff
of the 2 districts to avoid delay in file transmission but, at this stage, could not
centralise the work under a single office due to technical problem.
31. The operator found the said meeting useful and wished to have similar meetings
with FEHD when need arises. FEHD would try to address their needs.
Agenda 4 – Any other business
Set-up for supporting services made of fibre glass
32. One of the operators referred to paragraph (a)(5) Appendix 18 of the Application
Guide and asked whether certification or referral to BD and FSD would be required
if the change in set-up for supporting services (e.g. kiosk, ticketing office, candy
stores, etc) would not affect the means of escape and the fire service installations.
In reality, most of the set-ups of supporting services in the theme park were made
of fibre glasses.
33. BD explained that if the fibre glass structures were used for supporting services in
theme parks, no certification would be required. However, if it was a temporary
structure accessible by public, certification would be necessary upon BD’s request.
Deadline for submission of applications for temporary PPEL
34. According to the Application Guide, an application for temporary PPEL should be
submitted at least 42 days before commencement of the public entertainment. An
operator found difficulties to meet the timeframe.
35. FEHD replied that the “42-day” was a statutory requirement for those applications
involving building structures. FEHD adopted flexibility to consider individual
applications. The trade was advised to submit applications on time.
36. BD informed the meeting of the internal target to respond to FEHD’s referral of
PPE applications within 24 days.
Notes of the 5th
BLG meeting – Theme Park
8
Action
Food hawking in theme parks
37. To provide better customer service, the trade would like to peddle ice-creams,
hot-dogs, hot / cold drinks, etc along the queues of attractions. An operator
mentioned the existing independent quality assurance team responsible for
monitoring the food hygiene of the whole park. The trade considered that the
simple food preparation process coupled with well-trained food handlers would not
give rise to any food safety / hygiene issues and asked for a licence to be issued to
the theme park for the purposes.
38. FEHD said that trade could peddle non-restricted food e.g. canned drinks,
pre-packed snack, etc freely in theme parks. Restricted food like ice-creams
could only be sold in a “designed” location covered by a valid permit or licence as
appropriate. FEHD would not issue any hawker licences for mobile hawking of
restricted food in private places and theme parks were considered as “private
places”, where admission by payment would be required,.
39. The trade could hardly agree with FEHD’s interpretation which was different from
Interpretation and General Clauses Ordinances, Cap 1A where a theme park was
regarded as a public place.
40. The trade reiterated their operational needs for hawker food licences and urged the
Government to help maintain the competitiveness in view of the globalisation and
the operations of theme parks in other countries. They were ready to provide
more information where necessary.
41. The trade also noted the recent review of itinerant hawker licences for selling ice
cream and would like the subject of “food hawking in theme parks” be included in
that review. They hoped that their operational needs could be duly addressed by
the Administration. In particular, they asked the Government to take into account
the following factors in the course of the said review:
(a) the unique operational mode in theme parks;
(b) the high mobility park-goers;
(c) the need for customer service including mobile hawking of made-to-order food;
(d) technology development in securing hygienic food preparation in food carts; and
(e) the existence of independent quality assurance team for centrally monitoring the
food hygiene.
FEHD
EABFU
Notes of the 5th
BLG meeting – Theme Park
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Action
42. Besides, the trade wanted to know the policy objectives of / rationale for banning
the hawking licences; and the relevance of banning similar hawking activities in
well-managed theme parks.
43. FEHD understood the trade’s needs and would try to explore ways to facilitate
their business.
FEHD
FEHD
Deployment of EMSD’s staff
44. One of the operators found the concurrent staff changes at all levels in the team
regulating amusement rides. In view of the complexity of amusement rides, the
trade would like the staff to keep abreast of the latest development of amusement
rides and operations of theme parks, apart from the electrical and mechanical
aspects.
45. EMSD assured the trade that their staff were well experienced and competent to
regulate ride safety. A designated engineer has been following through the
re-development of a theme park with a view to further enhancing the
communication on safety issues.
Date of next meeting
46. The next meeting would be held in October 2008.
(Post-meeting notes : The next meeting will be held at 10:00 am on 15 Oct 2008. )
EABFU
Economic Analysis and Business Facilitation Unit
July 2008
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BLG meeting – Theme Park
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BLG meeting – Theme Park
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BLG meeting – Theme Park
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BLG meeting – Theme Park
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BLG meeting – Theme Park
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