INTERNATIONAL LABOUR OFFICE

STUDIES AND REPORTS
Series F, Second Section (Safety) No. 6

SAFETY IN THE MANUFACTURE
AND USE OF CELLULOID

GENEVA
1933
Published in t h e U n i t e d Kingdom
For t h e INTERNATIONAL LABOUR O F F I C E ( L E A G U E OF N A T I O N S )
By P . S. K I N G & SON, L t d .
Orchard House, 14 Great Smith Street, Westminster, London, S.W. 1

PRINTED

BY

ATAR, G E N E V A

PREFACE

The present monograph on safety in the manufacture and use
of celluloid continues the series of Studies and Reports on
industrial safety.
As long ago as its first session in 1925, the Correspondence
Committee on Accident Prevention suggested taking up this
problem, and proposed Dr. FISCHER, of Berlin, as Reporter.
Unfortunately, for reasons of health, this distinguished safety
expert could not complete the task embarked upon; but
Mr. STILLER, of the Federal Ministry of Labour in Berlin, who,
as adviser on questions affecting the safety of workers in the
manufacture and use of celluloid, was particularly conversant
with the subject, most obligingly offered to take his place.
. In January 1931 he presented the draft of the present
monograph, which was unanimously approved at the fifth
session of the Correspondence Committee, held in London in
May of the same year. The desires there expressed for additions
or alterations were confined to unimportant details, and consequently a second discussion by the full Committee could be
dispensed with, especially as Mr. STILLER had agreed to take
the Committee's desires into account in the draft.
The Office communicated the final text to the members of
the Committee, who had only a few observations to offer.
Some of these are of interest, however, as they are expressed
in a statement forwarded to the Committee by the Canadian
member, Mr. MORLEY, from the Eastman Kodak Company,
Rochester, New York, and thus convey the experience of
a very prominent American representative of the celluloid
industry.
The object of some of the Company's remarks was merely
to suggest additions, and these could be inserted without any
formalities; others, concerned with differences of opinion

VI

PREFACE

between American and European experts as to the best precautions to be taken, have been printed in extenso. It is hoped
that in this way the Office has rendered a useful service. In
no case were matters of principle involved.
Before concluding this Preface the Office must cordially
thank its collaborators, first and foremost the Reporter,
Mr. STILLER, and then the members of the Correspondence
Committee on Accident Prevention, who were helpful in furnishing material and expert advice. If the present monograph
contributes, in however slight a measure, to a reduction of
accidents in the extensive but particularly dangerous celluloid
industry, this will be the best reward for all those who have
assisted in its preparation.

CONTENTS
Page
PREFACE

v

PART I
THE MANUFACTURE AND USE OF CELLULOID AND THE
ELIMINATION OF THE ATTENDANT RISKS
CHAPTER I: General Survey
§ 1. Definition, Distribution, and Economic Importance of
Celluloid
§ 2. The Material and its Applications
General. — Celluloid Films. — Celluloid Solutions
and Lacquers.
§ 3. Dangers tor t h e Workers and Neighbourhood of Undertakings
§ 4 . "Varieties of Celluloid: Substitutes
CHAPTER I I : Technical Measures for the Protection of the Workers
and the Neighbourhood of Undertakings
§ 1 . The Manufacture of Nitrocellulose
§ 2. The Manufacture of Celluloid
§ 3. T h e Manufacture of Celluloid Goods
Building Regulations. — Works Regulations.
§ 4. T h e Manufacture of Film and Film Bases
§ 5. The Preparation of Cinematograph Films
§ 6. Celluloid Depots
§ 7. Homework
§ 8. Packing and Transport

1
1
2

5
8
II
11
13
19
29
35
39
43
44

PART I I
SAFETY REGULATIONS IN VARIOUS COUNTRIES
INTRODUCTORY N O T E

47

AUSTRIA

48

DENMARK

49

Order of t h e Ministry of Justice concerning t h e Storage of Celluloid Goods a n d Highly Inflammable Films
FRANCE

Order of 23 J u n e 1913 concerning Temporary Storage of Celluloid
Rules applicable t o Stocks of Crude or Processed Celluloid . .
GERMANY

Celluloid Order of 20 October 1930
Rules for t h e Protection of t h e Neighbourhood of Celluloid
Undertakings and Store-Places. Dated 5 November 1932
Safety Regulations for Celluloid of 21 July 1931

49
53

53
53
55

56
62
63

CONTENTS

VIII

Page

Model Safety Regulations for t h e Use and Storage of X - R a y
Films in Public H e a l t h and Welfare Institutions
Regulations concerning t h e Structural Arrangement and Installation of Cinematograph Theatres, and the Safety of Cinem a t o g r a p h Performances, 1926-1930
GREAT B R I T A I N

87
105

Celluloid Manufacture, Storage, etc., Regulations, 1928,
28 November 1921
Celluloid and Cinematograph Film Act, 1922
Order No. 4Ö3, dated 8 April 1924, respecting the Use of
m a t o g r a p h or Similar Apparatus in Film Stores
The Manufacture of Cinematograph Films Regulations,
dated 8 F e b r u a r y 1928. . . . .The Cinematograph Film Stripping Regulations, 1928,
11 February 1928
ITALY

80

-

dated
106
108
Cine114
1928,
114
dated
119
124

Regulations for t h e Prevention of Fires in the Commune of
Milan (22 April 1927)
124
Regulations for t h e Supervision of Theatres, dated 13 December
1923, w i t h Amendments of 28 March 1928
126
JWAN

132

Regulations No. 24 of the Department of the Interior, dated
20 J u n e 1929
132
SWEDEN

134

Royal Order to issue Certain Regulations concerning Films,
d a t e d 3 J u n e 1932
134
Royal Order to issue Certain Regulations concerning Cinemat o g r a p h Theatres and Cinematograph Performances, dated
3 J u n e 1932
145
SWITZERLAND

160

OTHER COUNTRIES

161

BIBLIOGRAPHY

163

PART I
THE MANUFACTURE AND USE OF CELLULOID AND
THE ELIMINATION OF THE ATTENDANT RISKS

CHAPTER I
GENERAL SURVEY

§ 1. — Definition, Distribution, and Economic Importance
of Celluloid
By celluloid is understood a horn-like substance obtained
by gelatinising nitrocellulose (collodion cotton) with camphor
or camphor substitutes, and. containing additions of filling,
colouring or softening materials.
Celluloid is an American discovery. During experiments
for the purpose of eliminating the explosiveness of gun-cotton
(invented in 1845), PARKES, in 1865, discovered a product that
could be used for waterproof coverings of clothes, for making
tubes, and for other purposes. This was called Parkesite.
After further experiments by SPILL, in 1869, the brothers
HYATT, of Albany, while seeking for a substance that could be
used for printing rolls, succeeded in producing celluloid on a
large scale. It was first put to use in the manufacture of billiard
balls.
The new material proved adaptable to many purposes;
and consequently soon — in 1878 — reached England, France
and Germany, where it was increasingly used in industry, and
worked in many ways. Its present commercial importance is
seen from the fact that the world production of crude celluloid
alone, excluding films, in 1926 has been computed at about
40 million kilograms.
Celluloid is made in only a few countries, and in them
only in large undertakings, six (and three small undertakings,

2

MANUFACTURE AND USE

RISKS

excluding film factories) being in Germany, three each in
France and the United States, two in Japan, and one each in
Austria, England, Switzerland and Italy. It is worked, however, in a large number of countries, mostly in numerous mediumsized and small undertakings. The total number of workers so
employed cannot be accurately stated 1 .
§ 2. — The Material and its Applications
GENERAL

Technically, the manufacture of celluloid is a relatively
simple process. Nitrocellulose is kneaded together with camphor,
and the resulting substance is stained.
According to W I L L and DUBOWITZ, commercial celluloid
(camphor celluloid) consists roughly of: 50-70 per cent, nitrocellulose with a nitrogen content of 10-11 per cent.; 15-35 per
cent, camphor; and 0-15 per cent, added substances — filling,
colouring and softening materials — which alter the properties
of the celluloid in different ways according to the purpose in
view. Other analyses have shown the added substances to
account for from 25 to 50 per cent, of the total weight. For
softening materials (plasticizers) use is made of vegetable oils
(e.g. castor oil), glycerine compounds, tricresyl phosphate, etc.
The commonest filling materials are gelatine, gum arabic, train
oil, borax, alumina and zinc white. The methods of mixing
these substances are mostly preserved as trade secrets, since
the properties of the finished goods depend on them to a high
degree.
Formerly, the camphor used was exclusively the natural
camphor obtained from Japan, China and Formosa, a distillation product of volatile camphor oil. It is a white, crystalline,
friable substance, very soluble in ether, alcohol, and certain
other liquids, but quite insoluble in water. It melts at 177° C,
but voiatises at ordinary temperatures. At the present time
synthetic camphor is also obtained from American oil of turpentine, and this variety is now used almost exclusively in
Germany. Several attempts have been made to replace camphor
entirely by other and cheaper substances, and, incidentally,
1
In Germany about 35,000-40,000; and in trade and in the film
business a further 12,000-15,000.

GENERAL SURVEY

3

to lessen the characteristic camphor odour of celluloid; but of
the countless patents taken put for this purpose, very few have
been actually worked. Among the substitutes proposed are
said to be chloral hydrate, urea compounds and chlorinated
hydrocarbons.
Crude celluloid is amorphous, transparent, very strong,
elastic, hard and very light (specific gravity about 1.4). Like
horn, it is unbreakable, and very tough. It possesses a fine,
slightly shiny surface. When uncoloured, and without additions,
it is seldom employed: transparent celluloid is mainly used for
safety glass in protective screens on motor-cars and other
vehicles. Usually it is stained with rather bright colours, which
can be done very easily, and in the most varied ways.
The finished celluloid has a shiny surface, is relatively hard,
and at ordinary temperatures rather insensitive to chemical
and mechanical action. It is also insoluble in water.
Celluloid is used for goods of all kinds. The following articles,
among others, when made of celluloid, consist entirely of
celluloid: combs, ornaments, balls, toy animals, dolls and other
playthings of different kinds; billiard balls, buttons, penholders, gramophone records, and plates for the manufacture
of galvanoplastie blocks. Celluloid is also worked in combination with other raw materials, sometimes as the preponderant
component, and sometimes forming only an insignificant part
of the finished article. Such use is exemplified by stuffed dolls
with celluloid heads, celluloid handles for umbrellas and sticks,
celluloid buttons and fastenings on clothes and shoes, celluloid
parts of electrical apparatus, celluloid coverings on boxes,
mirrors, ornaments, tooth and other brushes, spectacle frames,
writing materials, piano keys, and many other articles, not
excluding the celluloid tips of shoe laces. There is probably
no line of business in which goods with celluloid parts are not
to be found. They form part of the stock of establishments
selling articles ranging from writing materials and paper articles,
ladies' stockings, gold and silver ware, to provisions, drugs,
pianos and motor-cars.
CELLULOID FILMS

In addition to the celluloid that is used in the manufacture
of different kinds of goods, another type is produced which is

4

MANUFACTURE AND USE

RISKS

as clear as glass and sometimes, indeed, is used as a substitute
for glass. Its composition is as follows: 70-90 per cent, nitrocellulose with a nitrogen content of 11-12 per cent, and about
10 per cent, camphor. From this type are made the photographic films which, especially in the last decade, have given
such an impetus to amateur photography. All branches,
including sound films, of cinematography, which is so important
from the economic, artistic and technical standpoints at the
present time, owe their existence entirely to the celluloid films.
In radiography, films have completely ousted glass plates; and
they are very widely used in general photography (portrait and
amateur photography), in copying, and in aerial photography.
CELLULOID SOLUTIONS AND LACQUERS

Brief mention must also be made of a special use of celluloid.
Celluloid is soluble in an alcohol-ether mixture, in acetone, amyl
acetate, and other volatile substances. Such solutions have
been put on the market as colourless lacquers, mostly under
trade names 1. When dry they leave a thin vitreous pellicle
relatively insensitive to water, and they are thus useful for
coating highly polished metal surfaces to keep them from
tarnishing. Similarly, posters, signboards, the supporting surfaces of aircraft, etc., are coated with colourless lacquers of this
type to preserve them from the action of the weather. The more
recent quick-drying, brilliant, hard pigments (lakes), with
which wagons, motor-cars, furniture, etc., are coated (usually
by the spray process), also consist of celluloid solutions, mainly
derived from film waste, with the addition of suitable colours.
Only when the coating has to satisfy special requirements,
i.e. in the case of expensive lacquers, is nitrocellulose alone,
without any added camphor, combined with the solvent.
Viscous solutions of celluloid waste in acetone and other
liquids are used as adhesive and cementing materials for a new
type of shoe sole (Ago process), for example, as toecap stiffeners
in boot and shoe making, and to some extent in hat making.
Generally, however, the proportion of celluloid is very slight
in these solutions, but it must be remembered that the solvents
themselves are inflammable and explosive. The dangers can
1

In Germany: Zaponlack, Brossolin, Kristallin, Viktorialack, etc.

GENERAL

SURVEY

5

be diminished by the addition of other substances (colours,
etc.).
Reference must also be made to the manufacture of oilcloth
and similar materials in which sometimes a celluloid solution,
but more frequently a nitrocellulose solution alone, is laid or
pressed upon a foundation of linen or cotton fabric. Owing to
its close contact with the fabric, however, the lacquer coating
does not easily burn.
§ 3. — Dangers for the Workers and the Neighbourhood
of Undertakings
The useful properties of celluloid, which are responsible for
its wide and varied distribution, are unfortunately offset by
serious defects. It ignites very easily and burns with a very
smoky flame. One kilogram generates from 3,500 to 4,500
calories and, according toBoNwrrr, the combustion temperature
may reach 1,500-1,700° C. Particularly dangerous are the loose
scrap, shavings and dust produced in working-up processes.
Once alight celluloid burns with extraordinary rapidity, particularly in large quantities. It appears from information in the
technical press that in America 850 kg. of celluloid film was
consumed in three minutes in a testing chamber, and 32,000 lb.
in a Massachusetts warehouse in sixteen minutes. During a
big fire in Germany, about 50,000 kg. was consumed in an
hour; and in another, about 10,000 kg. in half an hour. The
rapidity of combustion is from fifteen to eighteen times that
of pine wood. In the course of combustion long and extraordinarily hot sheets of flame are observed. Not only the workrooms of the undertaking itself but also neighbouring premises
are threatened, especially those above the rooms in which
celluloid is worked.
Celluloid does not ignite or explode spontaneously, nor can
it be made to burn by mechanical action, such as friction,
shock or impact. But certain varieties can undergo flameless
decomposition at temperatures above 100° C , in the heat
radiated by steam and other heating systems for example;
or by continued exposure to a powerful electric lamp 1 . The
1

Since, when decomposing, celluloid supplies its own oxygen, such
decomposition can take place even in the absence of air.

6

MANUFACTURE AND USE

RISKS

resistance depends upon the composition, more particularly
the proportions of filling and colouring substances. In such
cases combustion is accompanied by clouds of inflammable
camphor fumes, oxides of nitrogen, carbon monoxide and
prussic acid, all of which are very poisonous and usually arise
in such quantities that all the air in the premises is speedily
forced out. The temperature may rise to 500-800° C ; and
1 gramme of celluloid gives off 600 c.c. of gas, containing 260 c.c.
of carbon monoxide, 150 c.c. of nitrous gases, and 5. or more c.c.
of prussic acid. The rest consists of camphor vapours, etc. The
prussic acid content is said to vary from 0.5 to 0.7 per cent.
The composition of the vapours given off depends upon the
type of celluloid. In a laboratory experiment 286 litres of
vapour given off by smouldering X-ray film contained 70 litres
of carbonic acid, 107 litres of carbon monoxide, 95 litres of
nitric oxide and 4 litres of prussic acid. If combustion takes
place in a sufficient supply of air, the prussic acid content is
substantially higher. Closed containers filled with celluloid,
e.g. safes for storing films, are liable to explode owing to the
internal pressure resulting from fire. Consequently provision
must be made for carrying off the vapours. In special circumstances the vapours given off in nameless decomposition can lead
to explosions when mixed with air, or even by themselves 1 .
The explosive limits lie between 9 and 40 per cent, in air.
Like many other kinds of dust, when thrown up in clouds in
air, celluloid dust can be exploded by sparks, or if it settles
on hot parts of machinery, etc., may decompose and flare up.
Attention must also be paid to a special danger. It has
already been stated that for radiography the celluloid film has
completely ousted the glass plate formerly in use. In hospitals,
clinics, X-ray institutes and private doctors' establishments,
large quantities of X-ray films accumulate, since they considerably facilitate and improve diagnosis. So long as a patient
is being treated the X-ray films must.be easily accessible;
and even when the treatment is ended they must be kept for
many years in case claims should be made for compensation
or pensions. Since the X-ray films are usually large, so as to
enable photographs to be taken of large areas of the body,
1

On this point, the Eastman Kodak Company, Rochester, New
York, states that this is contrary to any experience they have ever had
in tests carried out by them.

GENERAL

SURVEY

7

considerable quantities of them are soon accumulated in the
institutions — in large clinics stocks representing several tons
have come to notice. Generally speaking, the dangers of these
films have not been realised in such institutions, and consequently storage arrangements have been relatively careless.
As a matter of fact since both sides are covered with a thickness
of gelatine, these films are not so easy to ignite as others, but
recent events have shown the danger with unmistakable clearness. In the cellar of a quite new hospital in Cleveland, Ohio,
a large stock of such films was stored. A fire occurred, probably
owing to an electric light bulb coming into direct contact with
the film. This led to the ignition and decomposition of the
whole stock; large quantities of the poisonous gases given off
were conducted through the heating and ventilation pipes into
all parts of the hospital, and the sleeping patients were suffocated
in their beds. In half an hour 125 were killed and even rescuers
died some hours afterwards owing to inhalation of the nitrous
gases 1.
Thus, if suitable measures are not taken, the dangers to
which industrial workers, the neighbourhood of undertakings,
and the general public are exposed in the manufacture and
working of celluloid have been shown to lie in:
(a) the high inflammability of the celluloid and its raw
materials;
(ft) the ease with which celluloid is decomposed by radiated
heat, poisonous and in some cases explosive gases and
vapours being generated;
(c) the explosibility of nitrocellulose '«hen dry;
(d) the danger of ignition and explosion of the solvents;
(e) the noxious effects of any vapours and solvents inhaled.
Besides these specific dangers attention must be paid, as
in any other industry, to:
(/)

the general dangers inherent in the use of moving
mechanical equipment, of prime movers, machine
tools, etc.;
(g) the general dangers inherent in the use of steam for
heating, warming or cooking.
1
In various countries the handling and storage of X-ray films is
regulated by law.

8

MANUFACTURE AND USE

RISKS

In comparison with the accident risk, the risk to health is
of insignificant importance. Admittedly, intoxication by the
fumes of the solvents, and skin injuries due to the different
added substances, are not unthinkable; but so far they have
never actually been observed, except perhaps in spraying work
for the decoration of celluloid. The injuries to health caused
by the decomposition vapours of celluloid — carbon monoxide,
prussic acid and nitrous gases — are always the consequence
of accidents.
Celluloid has the reputation of being the safer to handle
— within the bounds of reason — the more carefully it is
manufactured. Carelessly made, e.g. insufficiently de-acidified,
raw material shows a stronger tendency to decompose at lower
temperatures than properly purified material. Accordingly,
for commercial celluloid it has often been intended, in Germany
for instance, to introduce minimum specifications concerning
the flash point, camphor content, etc. ; or to make manufacturers
reponsible for certifying the irreproachable quality of every
consignment of crude celluloid consigned from their premises.
This, however, it appears impossible to bring about. Reliable
verification of compliance with minimum specifications is not
easily attainable and furthermore the relationship between a
guarantee of quality and the article guaranteed is not lasting
either in industry or trade, since celluloid often passes through
several hands as a half-finished product, and all kinds of scraps
mixed together are bought by dealers for working up. Finally,
in international trade provision would have to be made for
official testing at frontiers for the not inconsiderable quantity
of imported goods. Various investigations in official chemical
institutes have shown t h a t for celluloid manufacture in large
undertakings there is no particular need for such regulations
at the moment. Such undertakings have the very greatest
interest in delivering faultless goods in order not to impair
their markets.
§ 4. — Varieties of Celluloid : Substitutes
In industrial circles attempts have long been made to eliminate the dangers inherent in standard celluloid by modifying
the composition of the crude celluloid and by introducing
substitutes closely resembling it.

GENERAL

SURVEY

9

In order to diminish the danger of ignition the nitrocellulose
content was reduced and more camphor added; and for the
same reason not easily combustible additional substances such
as aluminium salts, magnesium chloride, silicic acid and asbestos
were tried. The addition of a sufficient quantity of mineral dyestuffs, zinc white for example, serves the same purpose. So far
these experiments have not yielded a really safe celluloid with
identical properties. In most cases the working up of most of
these substances is more difficult: bending in hot water is not
possible, dyeing possibilities are limited, elasticity and durability are less, and softening occurs at too low a temperature.
But a series of substances have been found which, although
combustible, burn very slowly. In these the celluloid mainly
serves as a cementing material. Such substances can only be
used for strictly limited purposes, mostly as insulating material
in the electrical engineering industry.
Instead of merely altering the composition of ordinary
celluloid with a view to eliminating its dangers, efforts have
been made to discover quite other substitutes. Recently a
number of synthetic products have been placed on the market
capable of competing with celluloid for a number of purposes;
but none of them can fully replace it in every one of its countless uses.
A second method is to replace, as the basic substance, the
highly inflammable nitrocellulose (collodion cotton), by the not
easily combustible cellulose acetate.. This substance is obtained
by the interaction of cellulose, acetic anhydride and glacial
acetic acid in the presence of a catalyst, a process for which
various patents and secret formulae exist. By the addition of
camphor and other substances various proprietary compounds 1
are obtained, which are difficult to ignite and burn very slowly.
They are vitreous and are often used as a substitute for glass
in the construction of motor-cars, airships and aeroplanes, for
protective goggles, and in making unshatterable glass, etc.
The substitution of a slow-burning base for the celluloid
base is a matter of great consequence for the whole film industry,
as eliminating fire risks in studios and, more especially, in cinema
theatres. Under the designation "safety films" there are films
for various purposes on the market, made from cellulose acetate
1

In Germany, Zellon, Zellite, etc.

10

MANUFACTURE AND USE — RISKS

with suitable plasticizers. It may be taken that the difficulties
formerly in the way of manufacturing safety films equal in
photographic value to the celluloid film have been overcome.
The safety film, however, is of necessity always dearer than the
celluloid film. For one thing, the components are dearer; and,
moreover, in the case of the standard 35 mm. cinematograph
film, it does not wear so well. It can be shown only a few
times, and consequently, it is little used in the cinema industry.
On the other hand, the safety film has a complete monopoly
in amateur cinematography, which has recently become so
popular; in fact, for this purpose the film manufacturers have
succeeded in producing safety films of an entirely satisfactory
quality l . At the International Photographic Congress held in
London in 1928, the representatives of the American, British,
French and German film industries agreed that all so-called
small films for amateur photography (16 mm. and less) should
be manufactured exclusively as safety films. Here and there,
in Paris for example, regulations have been framed requiring
that only safety films shall be used for X-ray photography so
as to eliminate the risk of film fires in hospitals.
The difficulties of manufacturing efficient safe substitutes
for celluloid lie partly in the inability to reproduce its many
special properties, and partly in the cost. Most celluloid articles
are mass-production goods which are designed to last only a
short time, and must therefore be cheap.
As long as it remains impossible to make really safe celluloid,
so long must every single undertaking strive, by taking suitable
precautions, to achieve the highest possible degree of safety.
It would be well if safety regulations on this point were uniform
in all countries. The accumulated experience and knowledge
of the more advanced industrial countries clearly prove the
possibility of bringing this about. The following chapter will
describe the means.

1

The same is true of X-ray and portrait films.

CHAPTER II
TECHNICAL MEASURES FOR THE PROTECTION
OF THE WORKERS AND THE NEIGHBOURHOOD
OF UNDERTAKINGS

§ 1. — The Manufacture of Nitrocellulose
Most large modern celluloid factories make their own nitrocellulose; only small undertakings and a number of film factories
buy it ready made.
The cellulose — usually raw cotton (waste, linters), more
rarely cotton yarn and, for special varieties, cotton paper 1 — is
cleaned, freed from grease by washing in caustic soda, bleached
with sodium hypochlorite, and converted into nitrocellulose by
treatment with a mixture of nitric and sulphuric acids. What is
made is not true gun-cotton, or trinitrocellulose, with a nitrogen
content of 12 to 13.6 per cent., but the less highly nitrated
collodion cotton, or dinitrocellulose, with a nitrogen content
of only 10 to 12 per cent. The composition varies, however,
according to the type of celluloid to be made.
The nitrocellulose is broken up in crushing mills. It is then
thoroughly washed with water and steam and freed from all
traces of acid. On the careful performance of this work safety
depends to a considerable extent. Traces of acid remaining lead
to decomposition of the celluloid, and on this account the process
of de-acidification is called "stabilisation". The water, which is
an obstacle to further processing, is centrifuged, and part is also
driven out by alcohol in special processes.
In the older undertakings the workers were exposed to
risk in handling the acids used in nitrating, and in emptying
the nitrating vats and the centrifuges; they were also liable to
injury from the nitrous gases. The plant was usually installed
in one-storied buildings.
1
For explosives, use is made of purest bleached sulphite fibre in
the form of crape paper.

12

MANUFACTURE AND USE

RISKS

More recent undertakings are carried on in buildings of
more than one story. The process is fully automatic; the material in course of manufacture, from the nitrating stage to the
finished collodion cotton, runs continuously downwards through
closed appliances which do not require to be opened even for
filling and emptying. Hand transport is only necessary in
exceptional circumstances. The conveyance of the acids to
the storage containers and the plant is effected by compressed
air or acid-proof pumps. From the point of view of accident
prevention, the latter method is preferable; in fact, in the
United States serious accidents have occurred owing to the
conveyance of acids by compressed air. The nitrous gases are
exhausted so that the workers do not come into contact with
them. They are usually condensed by scrubbing in water or
caustic soda, a procedure that prevents the severe and often
fatal harm that such gases cause and which is not noticeable
until some hours after inhalation.
In older undertakings, in which manual processes cannot
be completely eliminated, aluminium forks and tongs must be
used in decanting. The workers should be provided with rubber
gloves, protective goggles and special clothing safeguarding
them against acid splashes. It is also advisable to issue special
working boots made of wood or, if the dangers from acids are
particularly serious, of rubber. In addition, shower-baths
should be installed at suitable places so as to make it possible
for employees to apply large quantities of water in case they
should get acid on them. Eye-baths should also be provided.
For this an ordinary faucet can be used, turned upside down,
or a drinking fountain; the faucet is preferable, as the drinking
fountain may become choked up when not running.
For any process in such undertakings where the vapours
cannot be entirely eliminated, the workers should use suitable
breathing apparatus.
Since dry collodion cotton is an explosive care must be
taken that the water or alcohol content never falls below
35 per cent, by weight; otherwise it will fall under the very
strict provisions of explosives legislation. Safety in transport,
storage and processing largely depends on the maintenance of
this proportion of moisture. Stocks must be tested as to the
moisture content. Danger may arise if the alcohol content in
the upper layers of the storage or transport containers (in the

PROTECTION OF WORKERS A N D NEIGHBOURHOOD

13

past usually wooden cases lined with zinc or lead) sinks owing
to evaporation. It is therefore better to use tightly closed iron
drums with which mere rolling suffices to prevent an unequal
distribution of the moisture. The drums should be stored in
the cool.
The store-rooms for collodion cotton are mostly built apart
from the rest of the factory premises. The windows should be
given a dull coating in order to avoid excessive heat from the
sun's rays. The camphor, alcohol and ether must be stored
quite separately from the collodion cotton in a special room.
These solvents should, as far as possible, be stored in underground tanks, in order to prevent fire from spreading from one
tank to another. For the conveyance of solvents use should be
made of pumps (preferably steam pumps) placed above the
tanks, to the exclusion of bottom outlets. With such an arrangement, the possibility of bad solvent spills, due to broken or
untight pipe connections, is minimised. The storage premises
are usually in brickwork, fire-resisting, of one story, and well
ventilated.
§ 2. — The Manufacture of Celluloid
In the manufacturing process the following stages can be
distinguished : kneading of the basic mass, purification and incorporation in calendering rolls, and finally the shaping and
seasoning of articles of trade. It is not possible to go into full
details here: each factory has its own methods and regards
them as trade secrets. The French and American processes are
said to differ fundamentally from the German.
In order to protect the whole plant as well as possible from
the risk of fire and explosion, the buildings should be extensively
subdivided by fire-resisting walls. In addition, the mixing,
kneading and compressing plants are frequently installed in
separate premises. The drying plant is always in special buildings, mostly in the form of large tunnels.
The first stage in the manufacturing process is to weigh up
the requisite quantities of collodion cotton, camphor, solvent
and added substances in metal containers in the mixing plant
and to dissolve the camphor. The usual solvent is ethyl alcohol;
methyl alcohol is sometimes used, but mainly only for denaturation.

14

MANUFACTURE AND USE

RISKS

The dissolved mass is kneaded in strongly built and tightly
closed machines having double-walled containers which can be
heated with hot water or cooled with cold.
Kneading is carried on for several hours at a temperature
of 50-60° C. The nitrocellulose fibres are completely destroyed
in the process and a uniform plastic mass resembling gelatine.
is produced without any actual chemical changes taking place.
When the process is completed the mass is cooled by filling the
jacket with cold water. Whenever technically possible, the
cover of the kneading machine should be automatically connected with the drive so as to prevent the workers from reaching
among the kneading arms. When the machinery'is stopped
the trough is opened and raised' and the tough sticky mass
emptied out into iron receptacles.
During incorporation, alcohol vapours escape and are
exhausted for subsequent recovery, as are all solvent vapours
given off in celluloid manufacture where this is at all possible
and profitable. Three processes are current, viz. condensation
by cooling; absorption in liquids such as heavy oils, cresol,
tetralin (tetrahydronaphthalene); and absorption by activated
carbon. All three have proved successful, and the choice
between them is conditioned by the type of manufacture.
In large undertakings, recovery usually takes place in completely enclosed apparatus housed in special buildings. In this
way a convenient method for reducing risks is combined with
economic advantages.
In favourable circumstances it is said that 98 per cent, of
the solvent can be recovered at a cost of about 20 per cent.
of its value; but it is likely that results differ widely.
In the raw materials, impurities such as iron chips, sand,
copper and grit sometimes accidentally occur. They may
subsequently make the surface of the finished celluloid unsightly,
damage the tools of the cutting machines, and also cause
sparking on fast-running tools and so start fires. Consequently,
the mass -must be purified in filter presses at high temperatures
and pressures (up to 400 atmospheres). This purification is
said to be very successful economically, as it reduces the waste
and lowers the risk. It must be admitted that the filter presses
themselves may occasionally be a cause of accidents; pistons have
been known to fly out. An Italian firm has erected an armoured
roof over the piston heads to prevent damage from this source.

PROTECTION OF WORKERS AND NEIGHBOURHOOD

15

In the second stage of manufacture, the purified and still
fairly plastic mass is freed from alcohol to enable it to harden.
It is then put in small metal containers and conveyed to the
calendering rolls on which it is incorporated. The rolls are similar
to those used in rubber manufacture and are heated up to 90° C.
Sometimes the added substances are mixed in here. The alcohol
evaporates down to 12-15 per cent. The rolls are also encased
so as to allow the alcohol vapours to be exhausted and led off
to the recovery plant. This arrangement has frequently given
good results. The mass, which adheres to the rolls like a thick
hide, is cut off in the course of the process and repeatedly
incorporated, by which means it becomes increasingly hard and
strong. For the protection of the workers an instantaneous
trip gear is necessary.
Any air sucked in and kneaded in at the rolls makes the
mass irregular and pervious. Consequently, for five to ten
hours it is left in hydraulic presses, heated by hot water, under
a pressure of 50-150 atmospheres and at a temperature of 7090° C. Then it is cooled and removed from the presses completely
homogeneous and free from bubbles. It can now be considered
as finished crude celluloid. The blocks are slowly cooled in
masonry containers under running water.
• Mention must also be made of the preparation of coloured
patterns. The basic colours are added to the monochromatic
mass either in the kneading machine or on the rolls. By rolling
in various coloured ingredients, clouded, marbled and veined
patterns can be produced. Also the thin sheets of various
colours can be laid one on another in hot presses and welded
together. If the block thus formed is cut slantingly a striped
pattern will result, and all imaginable designs are obtainable
by combining different patterns.
In addition to organic tar dyes and inorganic dyes (zinc
white, chrome yellow, etc.), frequent use is also made of animal
dyes — fish scales, for example — and metallic dyes, such as
bronze powder. It is possible to produce almost perfect imitations of marble, mother-of-pearl, amber, horn, tortoiseshell,
ivory and many other substances, so that celluloid can be used
for countless purposes. Both the shade and the design are
subject to abrupt changes of fashion, and consequently the
pattern cards of large undertakings comprise thousands of
varieties. It should be noted that some of the dyes may be

16

MANUFACTURE AND USE

RISKS

injurious to health, but since the injuries will depend upon the
type of dye and the extent of its use, this general remark must
suffice. Large undertakings, however, have long ceased to use
injurious dyes.
As crude celluloid cannot be used in the large blocks, usually
about 1.50 metres long, 50 cm. wide and 25 cm. thick, the crude
material is brought into commercial shapes and sizes. This is
a purely mechanical process. On planing machines similar to
those employed for metal working, the still rough, uneven and
also soiled surface is planed smooth and the block cut into
sheets to any desired thickness. The progressive refinement of
the machines used has enabled thicknesses down to V 2o mm.
to be obtained. The edges are evened on cutting machines
similar to those used in pasteboard manufacture. In addition
to slabs or thin sheets various shapes can also be planed,
for example rods with round, rectangular or triangular sections,
such as are used in making beads, fountain-pen holders, etc.
With these articles, however, the proportion of waste is comparatively high. Recently it has been found possible, on hydraulic
presses, to form the relatively plastic mass issuing from the
rolls at a temperature of 60-75° C. directly into strands of any
pattern and length; and also tubes of any diameter and thickness.
These have made quite new methods of treatment possible.
Apart from the large rectangular blocks described above,
cylindrical blocks of about 30 cm. diameter are also manufactured. These are very finely scaled oñ from the circumference inwards and converted into bands of the desired length.
Celluloid in the form of blocks, rods or tubes is not yet a
finished product: it has to be seasoned. In the drying house
the pieces are sorted; the slabs, bars, etc., are hung perpendicularly in drying conduits heated up to 40-55° C. In a strong
current of air generated by exhaustion, the celluloid slowly
— often in the course of many weeks — becomes very hard
and unalterable. If the slabs are to be given a brilliant surface
they are arranged in large stacks in heated polishing presses,
a highly polished metal sheet being inserted between each pair
of celluloid slabs. Under the influence of the heat the softened
surface takes on the high polish of the metal sheet after about
a quarter of an hour. Dull or patterned surfaces can also be
obtained in this way, or on rolls like those used for calendering.
The finished articles are stocked in storehouses without packing.

PROTECTION OF WORKERS AND NEIGHBOURHOOD

17

The machines and equipment used in the above-described
processes for working up celluloid are, it is true, adapted to
their special purposes, but as a rule they differ but little from
those for working iron, paper or wood. Safety devices are
necessary to the same extent as in these other industries; and
it is of importance to keep every source of ignition away from
the celluloid. Consequently frictional heat must be avoided
as much as possible, and so must the generation, accumulation
and blowing about of celluloid dust, which is most highly
inflammable. The heating of the premises should be effected
only by low-pressure steam, hot water or hot air. The piping
must be smooth so that dust can easily be removed, and must
be so laid that the celluloid cannot come nearer than 25-50 cm.
to a source of heat. Storage near or on the heating system must
be rendered quite impossible. Experience shows that, owing
to the working-up process, celluloid easily becomes charged
with static electricity at a high voltage, which may generate
sparks and so lead to ignition, especially when solvent vapours
are present, as in the kneading machines. It is essential to
carry off the charges by properly earthing the machines, appliances, etc. The nature of the measures to be taken will
depend entirely upon the circumstances of the undertaking.
On this point the earthing regulations for electrical plant in
force in several countries may afford some guidance. Where
solvents are run off from the storage tanks particularly high
voltages arise. The tanks should be earthed, and, in addition,
they should always be connected by a metal cable or chain to
the container into which the solvent is being conveyed, so as
to prevent the formation of static charges. Some undertakings
have also found a variety of good ways of earthing driving
belts, which can become electrified in dry rooms.
Accurate means must be used to keep the temperature
within safe limits in the kneading machines and hydraulic
presses; sometimes automatic alarm signals must be fitted.
Heating with hot water is best because, practically speaking,
the decomposition temperature is never reached. Care should
be taken, however, to see that celluloid is never subjected for
a long time to temperatures obtainable from hot water, because
decomposition might possibly set in if the celluloid were subjected to such temperatures for a number of hours, e.g. five
or six. In older plants steam-heated presses are still to be found
2

18

MANUFACTURE AND USE

RISKS

in which the temperature occasionally rises too high owing to
inadvertent increases in t h e steam pressure. In order to prevent
decomposition oí the celluloid a number of undertakings have
installed powerful sprinkling plant which either acts automatically, e.g. owing to the burning away of a small piece of celluloid
that opens a valve \ or can be set going by the press attendant,
or by means of a valve outside the room. Such plant prevents
ignition by flooding the machines and so cooling the celluloid.
It can also be profitably installed at other danger spots. A
watch should be kept for leakages in the exhaust ducts evacuating the solvent fumes. That a plentiiul supply of fire
extinguishers and hydrants must be available goes without
saying. Most large undertakings have their own fire brigade.
Information on the most suitable structural arrangements
is to be found in the annual reports of the factory inspectors
and also in descriptions of existing establishments published
in trade journals. Mention has already been made of complete
separation of different parts of the plant, either by distributing
it over a number of independent buildings or by putting up fireresisting walls in one large building. Sometimes the buildings
are one-storied. Opinions are divided as to the roofing. Some
consider wood permissible, as it quickly burns away in a fire
and so allows the flames to burn harmlessly upwards; others,
fearing that burning pieces of wood will be flung about and so
spread the fire, insist on the necessity of incombustible roofing.
I t has also been suggested that wooden roofs should be provided
with gravel filling, which, it is contended, would smother the
fire by falling in. This, however, appears doubtful. Concrete
roofs must have a very large skylight of thin glass — not wired
glass — so that even a slight increase in pressure will provide
the flames and smoke with an escape upwards. It is advisable
to place a wire net outside the skylight to protect it against
falling pieces of burning wood.
Sometimes the side walls of a building are extended 2 metres
and more above the roof so that in the event of a fire the flames
1
In the United States this type of control has not been found to
be very satisfactory, and for the past few years there has been on the
market a new device, known as the Lowe system, which is operated
by the rate of rise in temperature. "With this system, which is now
extensively used in the United States, the sprinklers can be set going
in from 6 to 8 seconds as against 55 to 60 seconds for the standard
automatic device.

PROTECTION OF WORKERS AND NEIGHBOURHOOD

19

are confined and are led upwards harmlessly as in a shaft.
The distances of the various buildings from one another must
be as large as possible. Their windows and doors must be so
placed as to be opposite the fire walls of the neighbouring
premises. Doors must be provided in large numbers, and must
open outwards.
Opinions as to the best protection against lightning have
changed during the last few years. Absolute reliance is no
longer placed in the efficacy of a lightning conductor on the
building itself; there is now a tendency to place conductors
at high positions in the vicinity, but only at such distances that
they afford protection. Metal roofs must be earthed. Indoor
electrical appliances must be installed in compliance with the
regulations for premises specially liable to fire (enclosed switches,
etc.). On many occasions when short circuits have occurred
molten drops of metal have fallen on celluloid and quickly
caused fires.
The importance of celluloid waste as a prominent factor in
the problem has already been indicated. It is produced in very
large quantities, in some processes amounting to 30 per cent.
of the total output. Owing to its comparatively large surface
it burns easily, and being soiled with oils and other substances
it readily decomposes. It should be removed at least twice in
every shift, stored in a special depot, e.g. in properly vented
vaults or in suitable tanks under water and quickly reabsorbed
in the manufacturing process.
§ 3. — The Manufacture of Celluloid Goods
What is the reason for the many and varied uses of celluloid ?
Simply this: the ease with which it can be worked in the most
Widely different ways. Like wood, paste-board and horn, it
can be easily cut, sawn, turned, drilled and milled. On being
heated up to 80 or 90° C. in hot water, for instance, or to a
greater extent at higher temperatures, it is so plastic that it
can be embossed by the application of slight pressure and bent
into any desired form. Thin sheets of it can be blown in moulds
into any hollow shape (e.g. dolls). It can be welded by the
application of heat alone and made to adhere by suitable
cements (solvents). These processes are scarcely, if at all,
injurious to the polished surface which, when cold, is relatively

20

MANUFACTURE AND USE

RISKS

hard and insensitive to chemical and mechanical action, nor
does dampness affect the polish for a considerable time.
This ease and variety with which celluloid can be worked
and the manifold uses to which it can be put have led to its
presence in countless medium-sized and small undertakings
in every country in the world. Sometimes working-up shops
are attached to crude-celluloid factories. Celluloid can be worked
in the following ways, each of which calls for special precautions:
(a) purely mechanically by saws, milling tools, drills,
turning lathes, and presses;
(b) by bending, pressing and embossing after warming;
(c) by cementing and welding when hot.
In most cases several consecutive processes are required in
the manufacture of a celluloid article — not to speak of subsequent embellishment b y the application of coloured patterns
with brushes or spraying pistols; and the affixing of beads,
metal parts, etc.
The risks lie in the high inflammability and the decomposability of celluloid; in the combustibility and explosibility
of the adhesives, and occasionally also their noxious effects;
and in the mechanical installation. The technical measures
for the elimination of these risks consist in structural precautions and working regulations, which latter must extend to
the workers' behaviour.
BUILDING REGULATIONS

On account of the very serious danger of fire in celluloid
factories, special provision must be made for good exits. It is
hardly possible to confine undertakings to one-storied buildings
in towns. In high buildings, if a fire breaks out, overlying
workrooms or offices are often in the greatest danger from the
mounting flames or from sudden damage to the floors, with
very grave consequences to the surprised workers. The different
floors should therefore be separated one from another by fireresisting material. Each floor must have an exit — at least
an adequate emergency staircase — that cannot be endangered
either by flames or smoke in the case of a fire in any neighbouring celluloid undertaking. The outside walls and any
walls separating the workrooms from the exits (stairs, landings)

PROTECTION OF WORKERS AND NEIGHBOURHOOD

21

must be massive. These separation walls must also be reinforced with iron to enable them to withstand lateral pressure,
and be securely anchored in the adjoining walls.
The supports, pillars, stays and joists must be fire-resisting
or given a fireproof covering. The floors must be free from
open seams, and easily washable; and where dust occurs the
walls also must be made washable. Windows must have ventilating flaps at the top and in no case be fitted with gratings.
In every workroom a window with an opening of at least 0.25
sq. metres in area must be so constructed that it is automatically
opened by an internal pressure of 6 kg. per sq. metre and thus
allow gases to escape in the event of a fire 1. The lower parts
of the windows must consist of casements within easy reach,
0.5 metre wide and at least 0.5 sq. metres in area. Window panes
must be made of thin glass, never wire glass, so that they can
be easily smashed. On the sunny side of the building the
windows must be given a dull coating, for an air bubble can
act as a burning glass and may cause a fire. Whenever possible
the windows of one building should face the walls of the next.
The type of door should suit the type of wall in which it
is placed. In massive fire-resisting walls there must be massive
fire-resisting doors that close automatically. Doors of oak
or teak at least 2 inches thick, with or without a covering of
sheet iron, have proved to be better than solid iron doors.
They must be made smokeproof by fitting into rabbets; otherwise in the event of a fire smoke may be forced into the neighbouring premises by the excess pressure, and sheets of flame
may penetrate them. If the doors lead directly into the open,
these requirements may be dispensed with. As to the best type
of door only a few indications can be offered. Whether they
should open outwards or inwards must be decided in each
individual case. If they open outwards they can be forced
apart by the internal pressure and so the flames may endanger
the neighbouring premises; but if they open inwards the excess
pressure may become so high that the workers cannot open
them and so find their escape cut off. Emergency doors should
practically always open outwards. It has been suggested that
instead of doors use should be made of shutters that can be
1
A suitable ventilating sash which opens automatically under
slight pressure has been brought on the market in the United States
and approved by the safety organisations there.

22

MANUFACTURE AND USE — RISKS

pushed upwards to the ceiling in iron guides; or of corrugated
iron roller shutters something like Venetian blinds. A new
patent type of door is divided vertically into two halves that
slide sideways into the wall as soon as anyone treads on the
threshold and shut automatically as soon as the threshold is
left again. With swing doors on a vertical axis, the pressure
on each side of the axis is the same, and theoretically they
should not open even under internal pressure, but in a panic
they usually fail to act owing to the rush of people.
All measures for the workers' safety should be framed with
an eye to the great rapidity with which celluloid burns. Lives
are endangered in a few seconds. The quickest possible escape
from the workrooms is thus the first essential. Every workroom must have two opposite exits leading either to the open
air or to separate staircases. The distance from the workplace
to the exit should not exceed 20 metres. Exits should be indicated by the word " E x i t " . Doors must be kept unlocked so
long as any persons are in the workrooms. Approaches should
not be obstructed by leaving goods, tools, etc., lying about.
In addition all undertakings on the same floor must have at
least one independent means of escape that could not be imperilled in the event of a fire in the celluloid factory; iron
emergency ladders — or where large numbers of hands are
employed, iron staircases — are sufficient.
Staircases must be massively built and the stairs fireresisting. They must be adequately lighted. At the top should
be fitted a ventilation flap that can be opened from the ground
floor.
The workrooms, passage ways, exits and stairs must be
adequately lighted by daylight or by electric light from lamps
with strong outer safety globes. Emergency lighting independent of the ordinary lighting plant, ensured by accumulators,
and comprising the staircases and exits is desirable. In smaller
undertakings reliable safety lamps may. be allowed for use in
case the ordinary lighting should fail.
For heating purposes only low-pressure steam and hot
water enter into consideration. Heating installations, parts of
which can become over-heated, or which connect up a number
of rooms (e.g. hot-air systems) are inadmissible. The heating
parts must have smooth surfaces. It must be forbidden to dry
celluloid on them; either the parts must be suitably installed

PROTECTION OF WORKEBS AND NEIGHBOURHOOD

23

or the upper surfaces must be slanting. Heating pipes must be
20 cm. above the floor. Iron stoves must be absolutely prohibited. In old premises tiled stoves may be allowed only if
they are in good condition and the actual heating is done
outside the workrooms and there are no iron parts in them.
Adequate ventilation must be provided, when necessary by
means of a ventilator. Ventilation shafts must be separated
from other parts of the premises in a fireproof manner. Chimneys and other piping conveying sparks must not be used for
ventilation purposes.
The electrical equipment must be installed and inspected
in compliance with the regulations for premises specially
liable to fire. Special attention must be devoted to protection against fire. What is required is so-called small extinguishing equipment; buckets, not too small, filled with
water are generally preferred. Hand fire extinguishers, which
must be suitably distributed over the premises and tested for
efficient working, are also very popular. They may be filled
with liquids, but carbonic acid gas extinguishers, dry extinguishers, and the recently invented foam extinguishers are
utilisable. Whatever the type it should not be too small, and
in any case only equipment recognised as reliable by the fire
brigade should be installed. If water pipes are laid down for
fire-extinguishing purposes, the cocks provided with hoses of
adequate length should be placed outside the workrooms,
on the staircase, for instance. The diameter of the piping must
be large enough to ensure a plentiful supply of water.
When any machinery presents the risk of local overheating
a spraying appliance can be fitted on it. The question of sprinkling plant in celluloid factories has not yet been fully settled :
in some quarters it is contended that combustion is so rapid
that the fusible plugs cannot be effective. Trials have therefore
been made with special ceiling valves released by strips of
celluloid which burn through instantaneously. These, however,
require constant attention as they are released too easily (see
footnote on page 18). It would appear that such plant is of
use only in preventing fires from spreading. At all events the
question of fighting fires in celluloid processes must be thoroughly gone into. Although it is necessary at the very outset
to direct a powerful stream of water on to the seat of the fire,
it is objected that in this way burning waste and dust is scattered

24

MANUFACTURE AND USE

RISKS

over a wider area and the fire thus helped to spread. A lowpressure jet is said to be preferable, but its range is not large.
Perhaps the real solution will be found to lie in the foam extinguisher, which smothers the burning parts, or in extinguishers
containing liquid carbon dioxide. It should be borne in mind,
however, that the decomposition of celluloid can take place
even in the absence of air. Therefore, when foam or carbon
dioxide is used on burning celluloid the flame is immediately
extinguished, but decomposition may continue accompanied
by the production of large quantities of dangerous gases.
It is important to keep in readiness in every room an incombustible woollen blanket in which any person who may
have caught alight can be quickly wrapped, so as to smother
the flames. In addition, by every workplace must be kept a
bucket filled with water, in which the worker'can throw burning
celluloid.
It is sometimes recommended that so-called fire screens
of incombustible material should be fitted above the windows
to keep escaping flames away from the walls and overlying
premises. In the event of a fire, however, fire-resisting screens
hamper the placing of escapes and the rescue of persons through
the windows.
It should be remembered that large workrooms should be
divided up into compartments by fire walls and that small
rooms may benefit from exemptions according to the quantity
of celluloid worked in a shift (if less than 30 kg. for example).
The measures set out above, which are primarily intended for
new buildings, cannot always be fully applied in existing buildings; but the principles underlying them should govern the
installation of all undertakings. Where only celluloid parts of
articles mainly made of other materials are worked, e.g. in
umbrella factories, brush factories, etc., it is desirable, as far
as at all practicable, to have a special room for them so as to
isolate the danger. Then only this room need comply with the
regulations, which, in undertakings manufacturing goods consisting entirely of celluloid, must apply to the entire plant.
W O R K S REGULATIONS

The best structural fire protection remains ineffective if all
possible care is not taken to eliminate the dangers by efficient

PROTECTION OF WORKERS AND NEIGHBOURHOOD

25

methods of management. To this end a large number of measures
are applicable, but are all the more difficult to carry out since,
unlike structural measures, they are not in the nature of a
precaution that is taken once for all, but require constant
attention.
The workers should not bring matches or lighters on to the
premises, or smoke in the workrooms or any rooms adjoining
them in which there is danger of fire. Prohibitions such as
these should be made known by means of notice boards.
The machines on which celluloid is sawn, drilled, milled
or turned must be protected against overheating and sparking.
Circular saw blades must run in a slot on the work-bench lined
with wood or bronze. In dry sawing the blade becomes hot,
the celluloid soft and the cut smeary. Hence cooling by running
water is necessary, by which means also the shavings are
moistened and prevented from flying around. When a row of
identical machines stand side by side a gutter for flushing can
be provided, and then the shavings must be caught up outside
the workroom and stored safely. A similar arrangement can
be made for turning, milling and screw cutting. It should,
however, be observed that there is an aversion to wetting,
since wet shavings are difficult to sell and the railways prohibit
their transport. Drying the shavings increases the risk. In
drilling, cooling by dripping oil should suffice, although all oil
or grease facilitates decomposition. That the shavings should
not be swept up together with other rubbish and burned need
not be emphasised. For waste and shavings, a special container
will be required with a self-closing lid fitting into a rabbet.
It will be useful to have it open by means of a treadle. Metal
bins are cheap and light; wooden bins are heavier, but resist
longer in the event of a fire. In every shift the shavings should
be collected by a special person.
As regards removal of shavings and dust, the best results
have been obtained in wood-working with ducts and a ventilator.
In celluloid working, however, opinions are divided as to their
utility. In corners and pockets of the ducts dust may accumulate, and it is said to have been observed that fires are
actually spread by being sucked through such plant, or started
by sparking in the ventilator. Whether it is possible to suck
the shavings through water as soon as they arise, so that they
are retained and only air is conveyed, has not yet been

26

MANUFACTURE AND USE

RISKS

sufficiently investigated. The whole question of dust exhaustion
must be examined on its merits in each undertaking, and
settled in accordance with local conditions. The type of process
will be the decisive factor. It will suffice to quote the manufacture of combs as an example; in some factories each tooth
is separately cut out by a circular saw; in others many are sawn
together; in others again pairs of combs are so stamped out
that the gap between the teeth of the one leaves material for
the teeth of the other. This accounts for the widely varying
nature and condition of scrap. What must be avoided at all
costs is the removal of celluloid scrap in exhaust plant for wood
shavings.
The heating of celluloid for bending is mostly done in hot
water, that is, if the polished surface so allows. If stronger
heating is required, e.g. in pressing out hair ornaments or in
making perforated patterns, warming plates and tables are
used. For many years these have been heated with gas, the
position of the flame being such that the celluloid cannot reach
it. The temperature is regulated by the worker. It is still
contended that this is the best system. A serious accident,
however, that cost many lives should not be overlooked. It
was caused by a workgirl who went to light a not easily accessible burner with a strip of celluloid; as this burned too quickly
she threw it away and it chanced to fall on scrap.
For a number of years some firms have been making warming plates heated by electrical resistances; they can certainly
be regulated fairly accurately, but it is alleged that they sometimes become too hot owing to voltage fluctuations in the mains.
Recently, automatic circuit breakers have been provided which
switch off the current at a certain temperature; and in the
optical industry the bending of celluloid in a current of air
that can be heated as desired by electrical resistances is said
to have proved successful.
Celluloid blowing is done in iron moulds in which the contours of the articles to be made, e.g. dolls, animals, balls, etc.,
are impressed in every detail. These moulds consist of two
parts which fit one over the other and hold two celluloid sheets
of suitable colour and size, or pieces of celluloid tubing of
suitable length, diameter and thickness. The injection of steam
makes the celluloid plastic, and stretches it until it completely
fills the mould. After a short cooling the article is finished,

PROTECTION OF WORKERS AND NEIGHBOURHOOD

27

only requiring painting and removal of the ridge. Generally
speaking, there is no danger of fire in places where this work
is done since they are damp. The workers should be protected
against excessive damp by aprons, footwear, and the provision
of floor grating at the workplaces. They must also be protected
against scalding by steam.
In all workrooms the workplaces must be so arranged that
alleys about 1.20 metres wide lead to the exits and are kept
free from all obstruction. Some undertakings have tñed isolating
neighbouring workplaces by iron sheeting and so hinder fires
from spreading ; but in this way dirt-holding corners are formed
and the general view of the workplaces impaired. Hence such
protection will not be expedient in every case. The density
of staff in the workrooms should only be such t h a t every worker
has at least 3 sq. metres floor space and 12 cub. metres air
space.
Including crude celluloid for processing, the quantity of
celluloid of all kinds at any workplace should in no circumstances
be more than is necessary for carrying on the work. Finished or
half-finished goods should be placed in the depot or in a special
sub-depot not later than at the end of the shift. After the close
of work nothing should be left lying about. A daily clearing
up is necessary as well as a thorough weekly washing. Inflammable adhesives or solvents, or colouring materials containing
them, should be present in the workrooms only in the quantities
required for the work in hand, and should in no case exceed
the needs of one shift. The best containers are permanently
closed metal cans with safety mesh in front of the delivery
opening. For the work-bench, hand containers fitted with a lid
and secured against tipping over are recommended.
Special attention should be paid to these measures in places
where mass production goods, e.g. dolls or toy balls, are made.
If these and other toys, such as children's rattles and balls,
are ornamented by spraying on colours, the spraying must be
done in special rooms provided with ventilation openings near
the ceiling and just above the floor. Usually the work is done
in metal cabins and in powerful exhaust ventilation, so that
the colour vapours can be collected and removed as completely
as possible. "When there are several such workplaces in one
room the partial vacuum becomes so high that the natural air
supply through windows and doors is insufficient and the

28

MANUFACTUHE AND USE

RISKS

draught is a noticeable disturbance. When this is so, suitable
quantities of fresh air, warmed in winter, should be introduced.
The exhausted air laden with the varnish and other vapours
should be driven into the open by the shortest way and discharged where there is no possibility of ignition. The piping
must be electrically earthed, for recent observations have shown
that even solvent vapours become charged with static electricity
when whirled about, especially when mixed with dust, as is
known to occur when liquids are decanted.
In addition, in rooms where solvent vapours may be present
it is of importance to maintain a high relative humidity of the
air in order to prevent the formation of static charges on
the equipment used. In the United States, for example, in
industries where inflammable vapours are generated, the air in
the workrooms is generally kept at a relative humidity of
60 per cent.
Special care is required in polishing celluloid. An application of solvent, e.g. amyl acetate, softens the surface and so
removes cracks, and subsequent drying will give a fine polish.
In this process electric charges easily accumulate, and consequently the workers must stand on well-earthed metal sheets
or metal grating. The practice sometimes followed in small
undertakings of heating solvents over an open flame and
holding the finished articles in the vapour given off is quite
unallowable. The vapours mixed with air may explode or injure
the respiratory organs or the eyes. Cleaning work should be
undertaken only with tools made of wood or bronze, which do
not give off sparks. Repairs are allowable only after the close
of work and when the workplaces and their immediate vicinity
have been thoroughly cleaned. Remains of varnish or solvents
should not be burned in furnaces.
It is impossible to describe in detail the countless varieties
of working-up processes, each of which is determined by the
nature of the article. In most cases many operations are required before an article is ready for delivery.
It is also within the province of accident prevention to inform
newly engaged workers of the dangers they run, and to remind
all workers of them at regular intervals. Foremen must see
that their men work carefully and properly, especially on
machines. Juvenile workers who, on account of their nimbleness and quickness, are indispensable on many jobs, sticking

PROTECTION OF WORKERS A.ND NEIGHBOURHOOD

29

on ornaments, beads, etc., should only be employed under the
responsible supervision of adults and on work for which it is
not necessary to warm the celluloid or use inflammable liquids,
and in which no dust or small scrap (shavings, sawdust)
is produced. It has been shown that the juveniles pay the
least heed to the dangers and that they are also given to
larking.
In view of the high inflammability of celluloid, in an outbreak of fire there is only one road to safety; to get out of the
workroom as quickly as possible. The workers should be told
how they are to behave and which are the shortest and safest
ways out. It is necessary to sound the fire alarm without notice
at regular intervals. This requires an interruption of only a few
minutes in the work and has proved extremely valuable. From
among the employees a few specially level-headed men should
be appointed to manipulate the hand fire extinguishers. Since
with nameless decomposition all breathable air is forced out
of the workrooms, and it is thus impossible to enter them, in
large establishments breathing apparatus or gas masks must
be kept in readiness, and the workers trained in their use.
Oxygen apparatus for resuscitation is also useful.
It is usual and indeed essential for the workers to change
their clothes, for the working clothes, soiled with celluloid dust
and soaked in solvents, are highly dangerous. The dressing
rooms should be situated in a fireproof place. Many are the
workers whose first step in a fire has been to try to save their
things, and who have lost their lives owing to this short delay.
In many large undertakings the workers' clothes are insured
against fire by the owner at his own expense, and the workers
so informed by notices.
§ 4. — The Manufacture of Films and Film Bases
It is necessary to distinguish the manufacture of the crude
film celluloid, the base, the coating of the base with the lightsensitive layer, and the careful packing that must afford protection against light and moisture. When unpacked the film
is highly inflammable on account of its large surface, but once
packed it is much less dangerous.
The crude celluloid from which films are made is in the
main manufactured in the same way as that for other articles.

30

MANUFACTURE AND USE

RISKS

The collodion cotton has a nitrogen content of from 11 to,
at the most, 12 per cent, and must be particularly pure. It
is gelatinised with pure camphor or, sometimes, other substances,
and in large quantities of solvent, e.g. alcohol, ether, acetone,
it is kneaded and dissolved until a viscous colourless solution
is obtained. This is carefully purified under high pressure in
filters until it is perfectly transparent and vitreous. The higher
proportion of solvents is accompanied by an increase in the risks
due to evaporation. The manufacturing processes are sometimes
so arranged that the solvent and the finished solution flow from
one floor to the next below by gravity alone. When pumps
are used special care should be taken to prevent the formation
of electric charges. For the collecting vessels and storage tanks,
safety devices (e.g. tell-tale glasses) are requisite. Any electric
lamps used to illuminate them must be so installed that ignition
is impossible even in case of a leakage. Instead of breakable
tell-tales it is advisable to use automatic gauges.
The completely transparent, viscous liquid is converted
on special spreading machines into strips from 1.50 to 2 metres
wide — the so-called bases. Two types of spreading machines
are used. The first consists of a copper cylinder at least 4 metres
in diameter; the other of endless bands stretched over two
smaller revolving cylinders. The surfaces of the bands or
cylinders must either be silvered and highly polished, or given
a highly polished coating, so that the sheets of film in course
of manufacture will be perfectly smooth. The celluloid solution
flows from an adjustable spreading appliance evenly over the
whole width of the revolving cylinder or the band on which,
owing to the high temperature and the evaporation of the
solvent, a pellicle forms. Its thickness can be accurately regulated down to 0.01 mm. by controlling the flow, for roll films,
for example, a thickness of 0.08 mm. is usual; for cinematograph
films, 0.13 mm., and for X-ray films, 0.2 mm. Recently, optical
instruments have been used to measure the thickness, so as to
avoid opening the spreading machines, an operation that has
caused a number of accidents in the past. After most of the
solvent has evaporated the pellicle soon becomes firm enough
to be taken off and dried more thoroughly by suitable processes.
It is given a thin coating of substratum so that the gelatine
emulsion will adhere when applied, and it is then cut into the

PROTECTION OF WORKERS AND NEIGHBOURHOOD

31

usual commercial lengths: for the cinema, e.g., rolls 300 metres
long, weighing from 45 to 60 kg.
Several spreading machines are usually housed together in
one large room. They are completely enclosed, partly to
protect the sensitive film from dust or accidental damage, and
partly to enable the large quantities of solvent present to be
easily exhausted for recovery. Various means are also adopted
to prevent the formation of explosive mixtures in the machines.
Either so much pure air is blown into them that the proportion
of vapours remains below the explosive limit, or the space under
the casing is filled with an inert gas so that no explosive mixture
at all can arise. The evaporated solvents are usually recovered
by the ordinary processes. The loss is said to be small. The film
rolls are either worked up on the premises or sold to other
factories.
In the manufacture of photographic films the bases are coated
with a light-sensitive layer (emulsion). To an aqueous gelatine
solution are added nitrate of silver and a potassium halide.
This leads to the formation of a light-sensitive silver halide in
the gelatine solution. The stiffened emulsion undergoes a number
of processes, after which it is re-melted, spread on the base in
machines, rapidly re-stiffened by cooling, and finally dried
at a fixed temperature and a constantly maintained degree of
humidity.
In the whole treatment of these bases, from the preparation of
the emulsion onwards, the processes must be carried on, owing
to the sensitiveness of the coating to light, exclusively in darkened
workrooms which may be illuminated by red lamps only to
the extent required to enable the workers to observe the necessary operations. Consequently the machines and apparatus
must be particularly well protected in order to counteract the
heightened risk. Where emulsions less sensitive to light are
treated, e.g. in making positive films, brighter lighting should
be provided. The windows are shut tight, so that artificial
ventilation is required. In most cases this is bound up with the
regulation of the temperature and humidity of the air, which
must be accurately controlled if the product is to be satisfactory.
In all cases the regulation of the atmosphere is of considerable importance. Into nearly all the rooms carefully purified
fresh air is blown. In summer it is cooled in large masonry
chimneys and in winter suitably warmed. In this way the

32

MANUFACTURE AND USE

RISKS

humidity is also adjusted, in most cases separately for each
process. The undertakings are usually traversed from end to
end by a comprehensive network of piping and distant indicators
(temperature, humidity). As an organic colloidal substance
gelatine is very liable to continuous changes in its properties
and composition. It should be noted that the refrigerating
machines, of which there is usually a large number, require the
same precautions varying with the cooling medium used —
carbonic acid, ammonia, etc., as in other undertakings.
Access to the darkened workrooms is afforded by "lightlocks ", i.e. short passages fitted at both ends with light-tight
doors interlocked so that one can only be opened when the other
is properly shut. Care must be taken that the interlocking
mechanism can be instantaneously disengaged in an emergency.
Better than "light-locks" are "labyrinths", which, however,
can only be constructed in new buildings. "With these the workrooms are so placed as to be reached from a dimly lighted
vestibule by way of an open passage taking many turns, so that
it is quite impossible for unsuitable light to penetrate. All
exits, emergency switches, control handles, fire blankets,
hydrants, etc., must be separately and clearly indicated by red
lamps bearing suitable inscriptions. The exits must be made
conspicuous by being painted with broad and striking coloured
bands that show up well in red light. In passages and lightlocks steps should be avoided; the width will depend upon
the number of employees.
Where owing to the large number of workers employed a
panic might break out in a room in the event of danger, emergency lighting, independent of the general.lighting installation,
should be provided by accumulators. This will not be necessary,
however, if work is done only in the daytime. It is disputed
whether steps should be taken to enable the room to be brightly
lighted instantaneously in the event of an accident ; all the products, most of them of considerable value, would be ruined;
and it is further contended that the workers would be so dazzled
that they would see less than in the red light to which they
are accustomed. Nevertheless, such an arrangement would
make it easier to find any injured workers who might be lying
on the floor. With a view to enabling the fire brigade to penetrate without difficulty into the dark rooms, regulations in some
countries prescribe that the shutters over the windows shall

PROTECTION OF WORKERS AND NEIGHBOURHOOD

33

always be made of wood. In France it is laid down that only
the side panels of shutters may be made of iron sheeting, the
centre panel having to be made of wood.
The film bases, and still more the light-sensitive gelatine coatings, are spoiled by being touched. Care must therefore be taken
that all the processes are carried on as far as possible automatically, and the workers required merely to perform a few simple
operations, or often only to watch the work, duties which should
be perfectly safe for both workers and products, even in the
dark. The mixing of the emulsion is observed exclusively
through tell-tales, as are maturing, decanting and melting.
The application of the coating to the base is effected quite
automatically in a machine, so that the worker has only to see
to the proper distribution and temperature. In the drying room,
100 metres or so long, where the films are hung on rollers in
folds reaching from the ceiling to the floor, constant attention
on the workers' part is entirely unnecessary. All rooms should
have numerous exits and be extensively subdivided.
The emulsioned, wide, and endless film strip is repeatedly
subjected to close examination, still in a dark red light. It is
then cut into the usual commercial sizes, namely, rectangles
6 x 9 , 9 x 1 2 , or 13x18 cm.; or into roll films for photographs
4 x 6 , 5 x 8 , 6 x 9 , 9 x 9 cm. etc.; or, again, converted into
cinematograph films generally 300 metres long, the standard
width being 35 mm. For this work large use is made of machines,
which run slowly in order to reduce the electrification of the
film as much as possible and to allow of careful supervision.
For the purpose of confining fires, the machines should
be installed singly in special cabins isolated by partitions.
The perforation of cinematograph films is an important process.
The punched scrap is collected separately and the dust removed
by exhaustion. The finished film rolls are first wrapped in red
waterproof paper or metal foil and then in black paper so as
to ensure adequate protection from the light. When wrapped
up the films are placed in metal boxes. All these many and varied
operations are performed automatically. The machines must be
equipped with safety devices, including easily accessible trip
gear. The severe requirements that the product must satisfy
compel undertakings to take far-reaching precautions, not
excluding protection of the workers. Films for X-ray photographs are usually manufactured in the sizes 18x24 and
3

34

MANUFACTURE AND USE

RISKS

24 x 30 cm. Unlike the ordinary photographic films, they have
a light-sensitive coating on both sides. Each film is tested
with particular care- to ensure its flawlessness and is then
placed in a black paper cover. A dozen films are packed
together.
Up to this stage the processes take place in the dark. COHIT
munication with the day-lit outside world is afforded only by
automatic "locks" through which the films slide after they
have been wrapped light-tight. The numerous machines for
printing, cutting the paper wrappings, cardboard-box making,
etc., work in daylight. They must be equipped with the same
safety devices as in the paper or printing industries. For the
case-making and nailing machines, etc., also, only the ordinary
precautions have to be taken!
For the extensive laboratories in which the whole course
of manufacture is controlled and regulated as closely as possible,
indications of a general nature cannot be given. It is customary
to investigate the chemical composition of the materials, the
photo-chemical properties of the finished product, its sensitiveness to light (in Scheiner, Watkins, Hurter-Driffield, etc.,
degrees), blackening, sensitiveness to colour, mechanical qualities, and durability in storage, in tropical heat and Arctic
cold.
In the manufacture of films, large quantities of scrap are
produced. Most of it is worked up on the premises, but there
are also undertakings which buy and work up scrap of all kinds,
sometimes importing shiploads from abroad. The aim is to
obtain celluloid in as pure a state as possible for making lacquers,
etc., and to recover the silver from the gelatine coating. Working
up in the factories themselves is a relatively simple matter, for
the properties of the scrap are known. But when scrap is bought
up no man knows its origin and composition : the films may
already have been treated for the removal of dyestuffs, or some
of them may have undergone chemical changes owing to prolonged and frequent heating (when being shown). The uncertainty about their composition adds greatly to the difficulties
of working up, and accidents are frequent in the undertakings
in question. Large quantities of scrap suddenly ignite, usually
giving off sheets of flame which have been known to scorch
everything within a radius of 50 metres, throwing fleeing
workers to the ground and burning them to death.

PBOTECTION OF WORKERS AND NEIGHBOURHOOD

35

The waste is cut up dry *, finely shredded on machines and
washed in vats by being stirred in hot water, which dissolves
the gelatine. Sometimes silver is precipitated from the solution
in chemical works. The washed celluloid is dried; the drying
temperature should not exceed 45° C. A constant watch must
be kept on the temperature by means of indicators, and it must
be kept within safe limits by reliable appliances. The drying
plant, usually drying chambers, which must be properly vented,
should be heated exclusively by air, the air itself being heated
in hot-water or low-pressure steam installations so as to exclude
all danger of overheating. It is best to authorise such installations only at a distance from closely built-over localities. The
premises should always be one-storied and must be at least
20 metres distant from one another. Packing rooms must be
separated from the workshops. Store-rooms must be at least
50 metres away from the nearest buildings — this includes the
workshops — occupied by persons, unless these buildings are
protected by fire-resisting walls or by an independent enclosing
wall. Workrooms in which loose scrap is present must have so
many exits that no workplace is more than 6 metres from the
nearest. At least half the exits must be on the side of the building
away from the store-rooms, but one exit must be so placed that
it cannot be endangered by a fire in the neighbouring building.
All windows must be so constructed that they can be instantly
used as exits.
It only remains to say that strict supervision is necessary
in undertakings working up celluloid.
§ 5. — The Preparation of Cinematograph Films
On the treatment of roll films and film packs by amateur
photographers, or in photographic studios or copying establishments, there is no need to say much. The quantities present
are small, as they are in the photographic businesses that
develop and copy ordinary films. But the case is different
with the treatment of cinematograph films, which has grown
into a large industry, consisting of a large network of separate
branches, and in which the technical processes are usually
bound up with extensive commercial activities and advertising.
1
A safer method, strongly recommended in the United States, is
to carry out the cutting operation under water sprays.

36

MANUFACTURE AND USE

RISKS

In addition to the establishments for the production of
acted films there are others for trick films, advertisement films
and for the composition of sub-titles, that is, the text linking
up the different scenes. Developing and copying are done in
special undertakings. Sometimes, again, distributive undertakings make themselves responsible for showing the films,
but usually confine themselves to their issue, recovery, examination, repair, "de-raining ", varnishing, gumming, etc. Still
other undertakings concern themselves with the sale of copies.
To all these must now be added the recently formed firms for
recording sound films, the separate treatment of the sound
bands, etc. When a film is worn out or perhaps has merely
become out of date, it passes into the hands of dealers for eventual working up. Sometimes the still utilisable parts serve as
toys 1 .
Thus films are constantly changing hands. The commercial
character of these undertakings entails a great deal of intercourse; and care must be taken that the workrooms are completely separated from the offices, depots for printed matter, etc.
Sometimes the arrangement is that the workrooms for wet
processes, which are less dangerous, are installed on lower
floors, and the dry processes carried out above them, preferably
on the top floor.
For the wet processes the exposed negative film is stretched
on racks in lengths of several metres, and, in large tanks filled
with alkaline developers, developed, fixed and washed in the
dark. There is need of means to protect the workers against
moisture — aprons, boots and floor grating at the workplaces
— and of rubber gloves to preserve them from the action of
the alkalis. Recently, films have been treated quite automatically
in developing machines in which they are drawn over rollers
through the various baths in succession. Whereas formerly
the washed film was dried on wooden frames that rotated at
high speed in dry air (risk of electric charges), drying is now
accomplished safely in drying chambers by an air blast.
The individual scenes, as yet unarranged, are tried for their
effect, and then the most effective parts are cut out and stuck
together to form a continuous narrative. Often, and especially
with open-air scenes, not more than 10 to 20 per cent, of the
1
In most of the larger cities and in many States of the U.S.A., the
use of such film strips in toy projectors is prohibited by law.

PROTECTION OF WORKERS AND NEIGHBOURHOOD

37

original remains. Cutting out and sticking together can only
be done by hand. In this way the negative film gradually
assumes its final form. From this the copies required for the
distributing firms are made on positive films, developed, variously manipulated and sometimes coloured.
As regards the structural arrangements of the workrooms,
the same regulations are required as for workrooms in which
celluloid goods are manufactured (see page 20). The assembling
rooms, where large quantities of loose film are present, and where
consequently the risk of fire is high, should be divided up. As
far as possible there should be only four workgirls in each
compartment, and not more than two at each worktable. If
for special technical reasons this latter figure has to be exceeded,
the worktables should be so protected from one another by
partitions that fires cannot immediately spread. Worktables
on which films are stuck together, tested by artificial light,
etc., should be illuminated only by electric lamps of about
10-15 watts, enclosed in a strong, dust-proof, transparent
cover.
The workgirls who do the sticking should only have the
smallest quantities of adhesive by them. The joins are scraped
smooth with a small knife and the shavings must fall into a
receptacle, preferably automatically. All film scrap should be
collected in closed containers and removed in the course of
every shift.
The manipulation of loose film necessitates much rolling
and unrolling. Owing to the rapid movements, films become
warm and are easily electrified when they are unrolled and
re-rolled directly on the bench; it is advisable to use metal
covers on the tables, or better still rotary metal stands that
are well earthed. In order to judge the effect of the film when
placed together, the producer has it repeatedly projected; in
distributing concerns it is also shown to hirers. For this purpose
small halls are used. The operator with his projector is usually
installed in a separate box, which need not, of course, satisfy
the same severe requirements as cinematograph theatres
open to the public; nevertheless, a number of precautions
are essential.
The operator's box must be at least 2 metres long ; have
a floor space of 6 sq. metres for the first, and 2 additional
sq. metres for each additional projector; and have a clear

38

MANUFACTURE AND USE

RISKS

height of at least 2.80 metres. Exits should lead only to the
open or to special landings. In copying undertakings where the
operator is constantly receiving directions from the persons
watching and testing the film, the box may be connected to
the " t h e a t r e " by an opening not exceeding 3 0 x 3 0 cm. and
closed automatically by an iron shutter that runs in guides
and falls when a retaining thread burns through. In distributing undertakings the operator's box should not be connected
in any way with the "theatre " or workrooms. The observation
port for the operator should not exceed 250 sq. cm. in area,
and the light port should not be larger than is required for the
passage of the projected beam. Both should be closed by glass
5 mm. thick. The operator's box must have a ventilation
opening, at least 0.25 sq. metres in area, leading directly into
the open air or to an isolated air shaft that opens automatically
when the internal pressure rises. Only absolutely necessary
switch gear, of a safe type and safely installed, should be placed
in the box. Not more than the quantity of film required for
the performance should be present, and this should be stored
in special containers made of hard wood or otherwise protected
against heat, and provided with a self-closing lid. A pail filled
with water and a fire-resisting blanket must be kept in readiness
as a protection against fire. Films should be shown only by
operators who have been officially examined in the working
of projectors. The projectors must comply with special requirements, which should be officially specified; among these is an
automatic device preventing the moving film from decomposing
and beginning to burn owing to the heat of the lamp as it passes
through the projector, as might happen in a few seconds if it
were stopped by a tear.
The distributing undertakings receive back the films when
shown, examine them for injuries, and touch them up. Some
importance has been acquired by the so-called "de-raining ",
whereby mechanical damage to the gelatine coating and the
film itself, due to repeated showing, is partly or wholly repaired.
This is done partly with solvents and partly with special refractive liquids. In addition to the other measures, attention
must be paid to means of protection against the dangers involved
in these processes.
The showing of films in cinema theatres cannot be dealt
with here. These theatres are usually covered by special regu-

PROTECTION OF WORKERS AND NEIGHBOURHOOD

39

lations, varying with local conditions, issued by building or
fire authorities for the protection of public safety x .
§ 6. — Celluloid Depots
Depots of widely different types exist, and the measures
to be taken for their safety will depend upon the type.
Depots in celluloid factories for very large supplies are
mostly installed in separate buildings. Wholesale depots are
of similar construction and can also be installed in separate
buildings when the circumstances of the locality permit. The
position is different in working-up undertakings, in which the
store-rooms for raw materials and finished goods must adjoin
the plant and accordingly must often be under one roof with the
workrooms. The store-rooms of retail establishments may also
require attention, but usually contain only small quantities.
The structural requirements for depots are, generally speaking, the same as for workshops. Since, in the event of a fire,
however, the large quantities of celluloid in the depots might
prove a very serious danger, precautions are called for. The
outside walls must either be massive, at least 25 cm. thick,
or consist of equally fire-resisting double walls separated by an
air space. They should be reinforced with iron to withstand
lateral pressure and should be anchored in the adjoining walls.
Every depot must have two exits. Lighting should be
exclusively by electric incandescent lamps with strong outer
safety globes. Hitherto heating has been prohibited, but since
the experience of the severe winter of 1929-1930 with temperatures of 25-30° C. below zero has shown that celluloid can
become brittle, it must be seen to what extent heating is permissible in individual cases. Smoking and bringing in matches
or igniters must be prohibited by notice. Good ventilation
must be provided. The vents must be so constructed that they
open automatically when the internal pressure rises. Sometimes
permanently open air ducts are met with. These usually have
a sharp bend in them to prevent flames or sparks from penetrating into the depot. The other openings, too, should be
protected against this danger by wire mesh or the like. Work
other than that in connection with the upkeep of the depot
1
Such regulations as have come to notice are reproduced below in
Part II.

40

MANUFACTURE AND USE — RISKS

must be permanently prohibited. Notices warning against
the danger of fire must be placed at the entrance. Only the
depot manager should be allowed admittance.
Depot roofs must be fire-resisting if other rooms be above.
For the top story of dangerous premises the bare roof can
serve as the ceiling when the neighbouring rooms are so protected
that fires cannot spread to them. It is sometimes advisable to
have lightly constructed roofs so that the flames can easily burn
upwards. If the depot is of one story the side walls may be
raised high above the roof so as to confine the flames.
An important point in depot construction is means of
limiting the quantities stored. Unfortunately, no general
rules can be framed. Broadly speaking, 4,000 kg. may be
taken as the highest quantity for one store-room. Several
store-rooms of this capacity are allowable when their position
makes it impossible for the fire to spread from one to another.
Where celluloid is stored exclusively in safes, or when, for
example, undeveloped cinematograph film is stored as required by transport regulations, the quantity for one room
may be raised to 10,000 kg. Specially favourable local conditions
may also permit an increase in the quantities stored. The extent
to which structural simplifications may fittingly be introduced
in small depots will depend entirely on the locality.
The protection of the depots against fire must be ensured
by outside hydrants or by sprinkling plant. In a large depot
for crude celluloid, satisfactory results have been obtained by
water pipes of such dimensions as to ensure direct and complete
flooding of the quantity stored, either automatically or at will.
In working-up establishments it is necessary to have depots
for the crude material, auxiliary material, half-finished or
finished products, and scrap. The crude material must be kept
apart in an outhouse or on a top floor in the conditions set out
above. Factory sub-depots are frequently isolated fireproof
from the workrooms, and are only used for the half-finished
products. Solvents should not be stored together with celluloid.
When directly under the roof, depots burn harmlessly upwards,
but depots in basements should be prohibited as endangering
the premises over them.
The practice of storing celluloid in water, formerly quite
common, impairs the quality of the goods and has been discontinued on this account.

PROTECTION OF WORKERS AND NEIGHBOURHOOD

41

The finished goods are packed and stored ready for consignment. In this state they are less dangerous, because the wrappings delay ignition.
The storage of celluloid goods in businesses raises many
questions. Large quantities are found in shops; and in this
case to allow only the top story to be used would be tantamount
to prohibiting sales altogether. Most of the articles, such as
chains, mirrors, boxes, buttons and caskets, which either consist
entirely of celluloid or are overlaid with celluloid, are bought
by passers-by and would find very little sale if customers were
put to the trouble of climbing stairs. Regulations for such
shops should always be drawn up by the fire authorities with
a view to public safety. But in any case celluloid goods must
be stored away from stoves, naked lights, and highly inflammable substances (ether, benzine, fireworks).
Large celluloid factories frequently maintain warehouses
in large towns, from which their customers can always be
supplied at once. At all events, their establishment is very
welcome, since they make it unnecessary to have many small
undertakings, and so reduce the risks. The requirements to be
satisfied by these wholesale depots can only be determined
by reference to each individual case.
For the storage of unexposed films for amateur, X-ray and
other branches of photography in retail establishments, no
regulations are required. Owing to the multiple light-proof
and waterproof wrapping (see above) they offer hardly any more
danger than paper. Forethought is required, however, in the
storage of exposed and developed cinematograph films and
X-ray films. The cinematograph negatives, in which the
entire cost of production has been absorbed, and of which no
duplicates exist, aie handled with the utmost care. They are
usually kept like archives, in fireproof iron compartment safes
in well-ventilated rooms, protected against heat and cold, on
top stories. They are always filed separately and kept under
lock and key in metal or pasteboard boxes.
Unless safety films are employed for the purpose of radiography, special attention should be paid to the storage of
X-ray films, especially in doctors' establishments, hospitals,
nursing homes, etc., where the inmates are more or less incapable
of movement. The requirements here may be graduated for
(a) quantities up to 5 kg. stored in consulting rooms of doctors

42

MANUFACTURE AND USE

RISKS

with their own practice; (b) quantities up to 5 kg. in places in
direct communication with hospital wards; (c) moderate quantities, up to about 150 kg., or (d) large quantities in big depots
and nursing-home archives, which in large towns may contain
several tons. In the great fire in Cleveland, U.S.A., it was
found that most of the 125 victims had succumbed to the
quick-acting carbon monoxide or to the after-effects of the
nitrous gases, no more than traces of which are injurious. Even
small quantities of film must be stored in hardwood boxes,
constructed so as to be poor conductors of heat and difficult
to burn. For moderate or large quantities film safes of a
most efficient type have recently been manufactured. They are
fireproof and the doors close in rabbets. The inner storage
chamber is divided into removable compartments, interlocked
mechanically so that only one can be opened at a time. Thus
a fire cannot spread from one to another. The inner chamber
itself is provided with a ventilation duct which by removing
any decomposition gases that may arise prevents explosions
occurring owing to an increase in pressure. Not more than 150 kg.
net weight of film should be placed in the whole safe and not
more than 40 kg. in any one compartment. Official fire tests
have fully confirmed the reliability of suitable types of these
safes, which are already in wide use.
The store-room for X-ray films should have no connection
with other rooms apart from the entrance hall and in any case
no connection with the wards or sick rooms. The structural
arrangements must meet the requirements already set forth.
There should be, first, a window 0.5 sq. metres in area of thin
glass, so that it will be broken by any slight increase in pressure,
and, secondly, a vent at least 0.25 sq. metres in area and opening
automatically at a pressure not exceeding 6 kg. per sq. metre,
that will lead off gases and vapours into the open. The heating
and lighting plants should be so installed that no films can
come into contact with them. In film depots no other objects
should be present and no extraneous work undertaken. Stocks
over 150 kg. should be housed in special buildings or on top
stories; here also the structural arrangements should be such
that in case of fire the gases and vapours can easily be led off.
Depots on top stories should be separated in a fireproof manner
from the rest of the premises. Prohibition of smoking, training
of the staff, and warning notices on the doors are self-evident

PROTECTION OF WORKERS AND NEIGHBOURHOOD

43

precautions. Unusable and unneeded films should not be
destroyed, but, like good films, be stored and disposed of to
dealers.
To the danger inherent in celluloid scrap reference has
already been made, but exposed film scrap is particularly
dangerous. It must be removed twice daily from the workrooms and stored in remote places, preferably in a special
room. Its collection in jute sacks cannot be allowed; the use
of strong boxes with tight-fitting lids is recommended.
§ 7. — Homework
In the manufacture of celluloid goods there are many
processes that can be carried out at home — for example,
inserting eyes in and attaching hair to dolls' heads, clothing
dolls' bodies, sewing celluloid buttons on to cards, levelling tooth
and other brushes, assembling sets of ornaments, and decorating
balls, finery, etc. Some time ago homework was widespread,
but of late it seems to have declined. The homeworker must
inevitably work under higher risks. He has only his living rooms
at his disposal and in them his family, including his children,
must pass their time. There is the cooking range with its open
fire, or other stove with an open grate. The children will play
near him. Lastly, the dwelling will in many cases be deficient
in exits. These are all circumstances that can be entirely
avoided in the processing of celluloid in industrial undertakings,
but cannot be overcome at home. If, in spite of all, more accidents have not occurred, the reason is twofold; for one thing,
with the homeworker the quantities in use are small, they
should not exceed 5 kg., and, for another, he knows that in case
of a fire his own small possessions would be the first to be
consumed. In Germany, in fact, only one such accident has come
to notice and in this the victims were two homeworkers. Strict
supervision is necessary. It is advisable, in addition to the
Government factory inspectors, to require the employer to
undertake regular inspections.
It should be arranged that the homeworker has only
enough celluloid on his workbench to ensure the continuance
of the work. Stocks and finished goods should be kept
locked up. The workplace must lie away from the fire
and from open lights. It is also advisable to do as the

44

MANUFACTURE AND USE

RISKS

goldsmith does: to make a semi-circular incision in the
bench and fasten on a piece of stuff to form a pocket, and
so collect falling scrap, etc. When, in the absence of electric
light, paraffin or gas lamps are used, they should be fixed at
a distance of one metre from the workbench and under them
should be placed metal dishes to collect oil, sparks, etc. Paraffin
lamps must be lighted outside the room; for lighting gas lamps
only Döbereiner lamps or cerium iron safety igniters are allowable. Smoking must, of course, be prohibited, but it will hardly
be possible to enforce the prohibition. Daily cleaning of the workrooms is necessary. The use of the kitchen as a workroom
should as a rule be prohibited; in special cases the most that
can be allowed is its use for non-dangerous work. Film strips
or scrap should neither be manipulated., processed, packed nor
otherwise dealt with. Lately it has also been attempted to prohibit all work in which scrap is produced by filing, scraping,
drilling, etc.; in which celluloid must be heated and softened
otherwise than in hot water; or in which inflammable liquids
must be used.
For extinguishing fires it is important to keep a pail full
of water and a wet dish cloth always in readiness at the workplace, so that any burning object can be picked up with the
cloth and dropped into the water.
It has proved very useful to distribute to homeworkers a
leaflet in which the dangers and the ways of preventing them
are brought to their notice.
Proposals have been made to prohibit homework altogether,
but in view of the present industrial situation the ensuing
distress of large numbers of workers, who could find no other
occupation, would be too great.
§ 8. — Packing and Transport
The nature of the packing will be determined first and
foremost by the manufacturer's desire to give his goods an
attractive appearance, so that they will find a readier market,
but to some extent also b y the need of protecting them from
injury or total destruction.
The manufacturer therefore arranges his packing on these
lines: the more expensive goods, such as finery, he puts in
handsomely decorated caskets; dolls he carefully wraps up in

PROTECTION OF WORKERS AND NEIGHBOURHOOD

45

tissue paper and lays in strong cardboard boxes; and films he
safeguards against any impairment of their durability. Further,
the public undertakings for transport and communications —
postal, railway and shipping administrations — have issued
packing regulations for their own protection. These are partly
national and partly international in scope, and mostly deal
with the specifications of packing cases or containers, maximum
weight, etc.
In addition, however, many other measures are necessary
to protect the workers during factory processes or transport.
Celluloid must frequently be packed in soldered metal boxes,
perhaps for consignment overseas. By contact with the soldering
irons a number of fires have been caused. Care must be taken
that the celluloid goods are covered with a material of low
combustibility, such as cardboard or asbestos, and that the
soldering is done with an iron as cool as possible, and outside
the workroom. The use of sealing-wax for cardboard boxes
should also be prohibited.
In large towns celluloid scrap is usually bought up by
special dealers and removed from the undertakings at regular
intervals — often, it must be said, in a careless manner. Use
should not be made of jute sacks which easily tear, but only
of strong linen bags. Accidents have already been caused by a
glowing cigarette-end being thrown away and chancing to fall
into an open sack on a passing lorry.
Cases must be assembled perfectly tight or lined with some
strong material such as cardboard. Smoking during transport
should be prohibited. Warehousing with a forwarding agent
should be allowed only for so long as is required for reconsignment purposes; otherwise scrap should be stored in a special
depot.

PART II
SAFETY REGULATIONS IN VARIOUS COUNTRIES

INTRODUCTORY NOTE
The technical measures described above in Chapter II are
the outcome of years of evolution and experience, and many are
the direct result of, or owe their nature and scope to, particular
accidents. Owing to the constant progress of technique, however,
many of them do not even now constitute the highest pinnacle
of wisdom. On several occasions explicit reference has been
made to the element of doubt in certain technical solutions
now adopted.
The dangers that the large number of working-up establishments entail for the workers, the vicinity and the general public
have long given the legislatures of a large number of countries
good grounds for concerning themselves with this domain.
The following pages summarise, to the extent that material has
been furnished or could be procured, the position in the different
countries.

LEGISLATIVE MEASURES

AUSTRIA
Regulations drawn up by the Ministries of Commerce, the
Interior, Railways, Public Works and National Defence, in
agreement with the Federal Ministry of War and issued on
15 July 1908 (Staatsgesetzblatt, No. 163) deal with the handling
of celluloid, celluloid goods and celluloid scrap. They contain
general provisions, technical provisions for workrooms and
depots, and also regulations applying to retail premises; further,
a Ministerial Order on the processing of celluloid by homeworkers, dated 12 December 1930, was promulgated in the
Austrian OfFicial Gazette {Bundesgesetzblatt für die Republik
Österreich) on 5 January 1931. Its provisions resemble those
of the German regulations.

DENMARK
There exist regulations for t h e storage of celluloid goods and
highly inflammable films under date of 20 March 1930.
Order of the Ministry of Justice concerning the Storage of Celluloid
Goods and Highly Inflammable Films 1
1. Celluloid goods must always be kept at a suitable distance from
other highly inflammable substances, bare lights, open Pres and other
radiators of heat. In addition, films must be suitably packed when the
stock exceeds 2 kg.
2. Not more than 2 kg. net of celluloid goods may be stored in
dwelling rooms.
3. Not more than 10 kg. may be stored in any store-room not
approved by the fire authorities. If several store-rooms are interconnected the quantity allowable per room is limited to 5 kg. and the
total quantity to 30 kg.
If, however, celluloid goods are kept in tightly closed cupboards
or other containers not holding more than 30 kg. each up to 60 kg. may
be stored in each room and up to 150 kg. in inter-connected rooms.
If films that are not suitably packed are stored, the cupboards or
containers must be made of oak or other wood suitably impregnated
or otherwise properly protected against fire, or metal adequately
isolated by asbestos.
Exposed X-ray films may be stored only in fireproof cupboards
or containers approved by the fire authorities. Not more than 120 kg.
may be stored in each room and not more than 150 kg. altogether in
inter-connected rooms.
In certain cases the fire authorities may allow double these quantities to be stored ; when such permission is granted for exposed X-ray
films, the cupboards for storing them may be required to be placed
against the outside walls and provided with exhaust ducts leading
directly into the open.
4. Larger stocks than those mentioned in section 3 may only be
stored in premises approved by the fire authorities. If the distance
between the different rooms is sufficient, the fire authorities may allow
the installation of several store-rooms in the same building. The
highest quantity to be stored in each room is fixed at 300 kg. net.
5. On the top iloor of a building, up to 4,500 kg. of celluloid may
be stored, provided that each room does not contain more than 1,500 kg.
and is approved by the fire authorities. If parts of this floor are used
for residential purposes these parts must be isolated from the store-place
by fireproof, explosion-proof and smoke-proof means and the storeplace must be provided with automatic sprinkling plant.
6. Film depots must be erected at such distance from habitations
that the latter are not exposed to any risk of fire, explosion or smoke.
1

Lovtidenden, A., 1930, No. 13.
4

50

LEGISLATIVE MEASURES

The distance may not be less than 20 metres without the approval of
the fire authorities.
7. Store-places for more than 4,500 kg. of celluloid may not be
erected without the special authorisation of the Ministry of Justice.
8. All store-places covered by sections 4 to 7 must be notified to the
fire authorities and the rooms may not be used until after approval by
these authorities and notification of the condition of storage.
9. As regards the processing, packing, consignment, etc., of films,
the rules prescribed by the fire authorities on the basis of the instructions
contained in Appendix III must be complied with.
. 10. While celluloid is being unpacked outside the store-rooms there
should be no fire or bare light in the vicinity.
Quantities of celluloid exceeding 100 kg. may not be unpacked
outside the undertaking's own buildings without the special authorisation of the fire authorities.
11. Penal provisions.
12. Any alterations required to bring formerly approved storerooms into harmony with the provisions of the present Order must be
carried out within two years after its coming into force; this period
may, however, be extended by the fire authorities in individual cases
for not more than two further years if circumstances so warrant.

APPENDIX I
Instructions for the Installation oí the Film Depots referred to in Section 4t
and holding up to 300 kg., in Buildings not used for Residential
Purposes
1. The store-room must be isolated in a fireproof manner from the
other rooms by walls, ceilings and floors of suitable thickness, and so
situated that no stairs can be rendered impassable or exits cut off by
any escaping flames or smoke.
2. The store-room must have ventilation openings of at least
400 sq. cm. each, for the inflow and outflow of air. Any flames or smoke
escaping from the ventilation shafts or windows should not endanger
any rooms over or next to the store-room. Any windows that may be
so endangered must be protected by wired glass at least 6 mm. thick,
cemented in or otherwise firmly built in.
3. Between the store-rooms and other rooms there must be a fire
lock, i.e. a fireproof vestibule with fire -resisting doors on both sides.
These doors must open outwards from the fire lock, be self-closing, and
fit tightly into rabbets.
4. Any chimneys that may be led through the store-room must be
suitably isolated. No fireplaces can be allowed. Any radiators must
be so protected that films cannot come into direct contact with them.
5. Only electricity may be used for artificial lighting; the installation must comply with the regulations drawn up by the Electricity
Commission for premises in which there is a danger of explosion.
6. The store-room must be kept locked when no one is in it.
7. An indication of its purpose and of the maximum quantity of
film authorised must be painted on the store-room door.
8. Films must be stored in boxes or similar receptacles. Not more
than 15 kg. of film waste may be present; the waste must be kept
in containers as required by section 3 of the Order.
9. Smoking or the use of a bare light is prohibited and notices to
this effect signed by the police or fire authorities must be posted up.

DENMARK

51

A P P E N D I X II
Instructions for the Installation of Film Depots holding up to 4,500 kg.
on the Top Floor of a Building when this Floor is not used for Residential Purposes and the Films are stored in Booms holding not more
than 1 kg. each
1. The walls, floors and ceilings of the store-room must be built
fireproof (solid masonry, or concrete a t least 15 cm. thick, or ferroconcrete a t least 8 cm. thick), and calculated t o withstand an internal
over-pressure of 0.2 kg. per sq. cm. The store-room m u s t afford good
communication with stairs and other exits.
2. From the store-room ceiling a fire-resisting and sufficiently
strongly built shaft with an internal cross section of at least 0.3 sq metres
must be led through the roof. The upper end of t h e shaft must be
tapered off and closed by wired glass not more t h a n 6 m m . thick, cemented in and not fastened in with clamps or the like. There may be
no other openings for light. At the lower and upper ends of the shaft,
and at least 2 metres from each other, there must be fitted two gratings
with sloping bars (45°) consisting of iron flats 5 m m . x 50 mm. The
bars may not be more t h a n 45 mm. apart.
3. The store-rooms must have ventilation openings near the floor
and the ceiling. The top opening must be made in t h e wall of the abovementioned shaft between the two gratings and provided with a similar
iron grating. The bottom opening must be so placed or protected t h a t
no escaping flames or smoke can endanger any neighbouring room.
4. (The same as paragraph 3 of Appendix I.)
5. (The same as paragraph 4 of Appendix I.)
6. (The same as paragraph 5 of Appendix I.)
7. For rooms in which films are stored the installation of sprinklers
may be required, as follows: two sprinklers per store-room together
with one sprinkler in the overlying shaft. All three sprinklers must be
fitted on t h e ceiling and provided with a common fusing piece (melting
point 70° C ) .
8. (The same as paragraph 6 of Appendix I.)
9. (The same as paragraph 7 of Appendix I.)
10. (The same as paragraph 8 of Appendix I.)
11. (The same as paragraph 9 of Appendix I.)
APPENDIX III
Instructions for the Processing, Packing, Consignment, etc., of Films
1. From every room used for the processing, packing, consignment,
etc., of films there should be means of communication t o a t least two
mutually independent exits.
2. Workrooms, packing rooms, etc., must be well ventilated and
isolated in a fireproof manner from the other rooms b y means of walls,
ceilings and floors of suitable thickness. The doors giving access t o these
rooms should be fire-resisting or in any case consist on the inside of
wood covered with iron. They must open outwards, be self-closing, and
fit tightly into rabbets. (Here follow the provisions of paragraphs 4
and 5 of Appendix I.)
3. In no workroom may more t h a n four persons be employed or
more t h a n 80 kg. of film be stored a t the same t i m e . If in a n y room
more t h a n two persons are employed at the same t i m e or any room
contains more t h a n 40 kg. of film, it must be provided with two suitably
arranged exits. Film waste must be stored in a receptacle fitted with a
lid and kept closed. The waste must be removed from the rooms
daily.

52

LEGISLATIVE MEASURES

4. As a rule, not more than 100 kg. of film may be brought into the
packing rooms at one time and packed or unpacked. As regards packing
rooms situated on top floors, connected with other rooms by a passage
only, and otherwise complying with the provisions of Appendix I
(including a Are door but excluding a fire lock as specified in paragraph 3)
the fire authorities may authorise the presence at certain times of not
more than 300 kg. fully packed film.
5. The indications prescribed in paragraph 7 of Appendix I must
be painted on the doors of all workrooms and packing rooms.
6. Films may only be stored and transported in boxes or similar
receptacles.
7. In rooms in which films are processed or packed a suitable
number of asbestos covers at least 1 xl.50 metres must be conveniently
hung at places within easy reach for the protection of persons and the
smothering of burning films. The workers must be given instructions
that when films catch fire, the untouched stock should be removed or
protected to the extent that circumstances allow.
8. For rooms in which films are processed or packed, and for passages, etc., sprinkling plant as specified by the fire authorities may be
prescribed if circumstances so require.
9. Smoking or the use of a bare light is prohibited in such rooms,
and the notices prescribed in paragraph 9 of Appendix I must be
posted up.

FRANCE
In France, undertakings in which celluloid is manufactured,
processed or stored, are subject to t h e regulations concerning
dangerous, unhealthy or noxious undertakings {établissements
dangereux, insalubres ou incommodes), and as such m u s t comply
with t h e requirements laid down in each individual case.
In some D e p a r t m e n t s there are police regulations for small
celluloid stocks. Below are given those in force in t h e Seine
Department.
Order of 23 June 1913 concerning Temporary Storage of Celluloid1
Section 1. — Brokers, packers and other dealers who temporarily
store celluloid in their store-houses shall be required, as from the
publication of the present Order, to notify this in advance to the Prefecture of Police (Sub-Direction of Accounts and Materials, Fire
Service).
Section 2. —• The handling of this inflammable substance shall be
subject to the following requirements:
1. The operations of packing celluloid articles, comprising soldering
and sealing with wax by means of a flame, shall be carried on in
premises separate from the store-place containing the celluloid and, as
far as possible, wide open.
2. Soldering and sealing with wax shall not be done on packing
in direct contact with the celluloid.
For these operations double packing shall be required, the outer
being a non-conductor of heat and made of cardboard, wood, etc., of
sufficient thickness.
Metal cases used for packing celluloid shall be such as to enable the
lid to be soldered without any trace of solder being able to penetrate
into the case, especially at the corners.
3. Packets or cardboard boxes containing celluloid for packing in
metal cases shall not be brought into the special premises for packing
unless provided with a very conspicuous label bearing the word
"Celluloid".
Bules applicable to Stocks of Crude or Processed Celluloid 2
(Quantity stored, even temporarily, between 10 and 50 kg.)
A. Crude celluloid
1. The store-place, including the ground, shall be made of fireresisting material with no wood exposed; it shall be provided with
wide windows.
1
Législation et nomenclature des établissements dangereux, insalubres
ou incommodes. — République
Française, Département de la Seine,
Préfecture
de police (2 m e Direction — 2 m e Bureau), Paris, 1925.
2
Législation et nomenclature des établissements dangereux, insalubres
ou incommodes. — République
Française, Département de la Seine,
Préfecture de police (2 m e Direction — 2 m e Bureau), Paris, 1925.

54

LEGISLATIVE

MEASURES

2. It shall allow of easy egress, the doors shall open outwards.
3. It shall not be heated. It shall be prohibited to light or bring
a fire into it or to enter it with a light.
4. Extinguishers and pails full of water shall be placed in the storeplace and close by outside.
5. If the store-place is in a building inhabited or occupied by
persons, it shall also comply with the following requirements :
(a) It shall be on the topmost floor inhabited or occupied, and shall
not command a staircase or any other means of egress.
(b) The entrance shall be closed by a vestibule having two doors
made of fire-resisting materials and closing automatically.
(c) The celluloid shall be kept in boxes. The total weight of each
box, including the contents, shall not exceed 20 kg.
B. Processed Celluloid
1. The stock of celluloid shall be subdivided as much as possible
and distributed in drawers or boxes made of hard wood or faced with
metal sheeting; cardboard boxes shall not be allowed except for fragile
articles in small quantities.
2. Drawers or boxes containing celluloid shall be as far as possible
from the exit door; they shall be kept at a distance from light fittings,
fireplaces, chimney shafts and electrical conductors.
3. Extinguishers and pails full of water shall be kept in the storeplace.
4. If the store-place is in a building inhabited or occupied by persons,
it shall be provided with wide windows. Not more than 500 grm. of
celluloid per cubic metre shall be stored therein.
5. When a testing workshop or a hall for showing cinematograph
films adjoins a film store, it shall be completely separated therefrom
by a wall made of fire-resisting materials. The workshop shall not
contain, even temporarily, more than 10 kg. of films. It shall always
be kept clean and tidy and provided with extinguishers and pails full
of water.

GERMANY
Formerly, uniform legislation applying to the whole country
was confined to the working of celluloid at home, which
was regulated by Orders of the Federal Minister of Labour
dated 4 May 1923 and 29 June 1927 (Reichsgesetzblatt, I, 1923,
p. 289; and 1927, p. 137). For celluloid goods there were different
types of regulation in the different States. In Prussia the Minister
for Commerce and Industry had issued principles for the inspection by factory inspectors of establishments for the manufacture
of celluloid goods and of their depots (7 May 1910 and 11 December 1911); and principles governing the requirements to be
laid down in respect of celluloid depots. The subject matter of
these regulations has been incorporated in the legislation of
various States, some of which, Bavaria, Saxony, Württemberg,
for example, have embodied it in police regulations. In addition,
in Prussia and other States there were in existence principles
for the inspection by factory inspectors of establishments in
which celluloid films were produced, processed, tested, repaired,
sold or shown. For the Berlin municipal district there was a
Police Order concerning notification of the working of celluloid,
the production of celluloid goods, and the storage of celluloid
or celluloid goods in quantities of 50 kg. or more.
These earlier regulations varied widely in form and were no
longer sufficiently comprehensive in substance owing to the
growing use of celluloid. Accordingly, the Federal Minister of
Labour, following upon several accidents, issued regulations on
20 October 1930 (Reichsgesetzblatt, I, p. 468) that constitute
uniform legislation of the widest possible scope for the entire
Reich. They are brief and contain only administrative provisions, which do not require much alteration. They make
provision for the issue of safety regulations in a flexible and
adaptable form, and these it is easy to amend.
For the framing of the safety regulations a Federal Committee
for Celluloid was set up. It consists of representatives of the
authorities, employers and workers in every branch of the
industry and is therefore particularly competent. The new
regulations were issued on 21 July 1931 (Reichsarbeitsblatt,
p. 165). All earlier regulations will be withdrawn.
It should be observed that for administrative reasons the
Federal regulations extend only to the protection of workers in

56

LEGISLATIVE MEASURES

industrial undertakings, the protection of the neighbourhood
being dealt with in the legislation of the different States. It
is of importance, however, that owing to the far-reaching effects
of accidents due to celluloid, measures taken to protect the
workers should protect the neighbourhood also. (This distinction
was not made in the survey contained in Chapter II.) A number
of mutual accident insurance associations (Berufsgenossenschaften) whose members are engaged in the treatment of celluloid
have also issued regulations, which in substance resemble those
mentioned in Chapter II, but usually deal with details.
For the use and storage of X-ray films in institutions connected with health and welfare uniform regulations have been
issued under date of 11 June 1931 by the Federal Ministry of the
Interior and are now in force as police regulations in the various
States.
For cinematograph theatres, uniform police regulations
based on a Federal model have been issued in the various States
respecting, for example, the arrangement and equipment of the
theatres and the safety of the performances.
Undertakings manufacturing celluloid require a licence under
section 16 of the Federal Industrial Code.
Celluloid Order of 20 October 1930 *
1. Scope
This Order shall apply to industrial establishments :
(1) in which celluloid or celluloid waste is treated or processed,
whether alone or in conjunction with other substances, or
celluloid goods are manufactured ;
(2) in which celluloid film bases are coated with a light-sensitive
layer;
(3) in which celluloid cinematograph films are treated (in particular, developed, copied, assembled, repaired, touched up,
washed), packed, hired out or sold, including theatres in such
establishments ;
(4) in which the materials mentioned in Nos. (1) to (3) are stored;
(5) which are regularly engaged in the transport of the articles
¡¡¿¿ß mentioned in Nos. (1) to (3), excluding transport by post, rail
or ship.
This Order shall not apply to homeworkers, workshops in which
the processes specified in No. (1) of the first paragraph are carried on,
except where this is specially indicated.
1

Reichsgesetzblatt, I, p. 468.

GERMANY

57

2. Definitions
"Celluloid " within the meaning of section 1 of this Order shall mean
horn-like substances which are obtained by gelatinising nitrocellulose
(collodion cotton) with camphor or camphor substitutes and may
contain additions consisting of colouring materials, filling materials
or plasticisers.
Substances of the kind specified in the first paragraph which owing
to their special composition are inflammable, but once ignited burn
slowly, shall not be subject to this Order, if the Federal Minister of
Labour so decides after consultation with the Federal Celluloid Committee (section 18).
References to celluloid in the following provisions shall be deemed
to include celluloid goods, celluloid films and celluloid waste.
3. Exceptions
This Order shall not apply to:
(1) establishments mentioned in Nos. (2) and (3), of the first
paragraph of section 1 which form part of plant for the manufacture of celluloid requiring a licence under section 16 of the
Industrial Code;
(2) establishments for the manufacture of celluloid lacquers;
(3) the handling and storage of films in X-ray laboratories,
hospitals, curative and nursing establishments;
(4) production of motion pictures (cinematograph studios);
(5) cinematograph performances except where they are given in
establishments mentioned in No. (3) of the first paragraph of
section 1.
4. Limitation of Scope
This Order shall apply to all establishments of the kind specified
in section 1, where the quantity of celluloid in any workroom or series
of directly inter-communicating workrooms exceeds 5 kg. even only
occasionally. The Order shall apply to store-rooms in which more than
25 kg. of loose celluloid, or in the case of commercial packing, more than
150 kg. including the packing materials are stored.
The Order shall not apply to shops unless they offer for sale goods
consisting wholly or mainly of celluloid in quantities exceeding 5 kg.,
in the case of commercial packing, in quantities exceeding 25 kg., or,
in the case of films, in quantities exceeding 50 kg. including packing
materials.
5. Duty of Notification
Any person desirous of opening or transferring an establishment of
the kind mentioned in section 1 read in conjunction with sections 3 and
4 shall notify the competent industrial inspection official thereof not
less than a fortnight before the opening or transfer.
Similarly, occupiers of existing undertakings subject to this Order
shall furnish a notification within four weeks of the coming into
operation of this Order.
The person responsible for making the notification prescribed in
paragraphs (1) and (2) shall communicate a copy to the accident
association (Berufsgenossenschaff) competent for the establishment.

58

LEGISLATIVE MEASURES

6. Contents of the Notification .
The notification shall contain the following particulars:
(a) the business style of the occupier and name of the responsible
manager;
(b) a plan of the site showing the distance from neighbouring
buildings and the purposes that they serve, and, in the case of
buildings with two or more stories, a plan of the workrooms with
an indication of their use, the approaches and thé floors above
and below them;
(c) the processes carried on and the nature of the articles to be
manufactured, stored or consigned;
(d) the estimated maximum quantities of celluloid to be processed
in one day, and to be stored in each workroom and store-room;
(e) the estimated number of workers to be employed, men, women
and young persons to be shown separately.
7. Safety Regulations
With respect to their plant and methods of working, the establishments subject to this Order, including homeworkers' workshops, shall
comply with the safety regulations framed by the Federal Celluloid
Committee (section 18), and put into operation by the Federal Minister
of Labour.
The employer, and in a homeworker's workshop the homeworker
shall see that the regulations are observed by all persons on the
premises, including those only temporarily present.
8. Employment of Young Workers
Workers under eighteen years of age shall not be employed in the
treatment and processing of celluloid, except on work for which the
Federal Celluloid Committee has expressly declared in the safety
regulations that their employment is open to no objection. In this
connection, provision shall be made for adequate supervision by
experienced adults designated by the employer.
9. Cloakrooms
Garments shall not be removed in the workrooms. The employer
shall provide as a cloakroom for the persons employed in the undertaking a closed room apart from the endangered workrooms, protected
as far as possible against fire, and having safe means of access. In
individual cases where special precautions are taken for the safety
of workers and clothing the industrial inspection official shall be
empowered to authorise exceptions.
10. Instruction of the Workers
The employer shall hand the leaflet compiled by the Federal
Celluloid Committee to all workers employed in the treatment, processing or consignment of celluloid. If the undertaking has rules of
employment, the leaflet may be annexed to them. The employer shall
give instructions respecting the contents of the leaflet and especially
the use of dangerous machinery to persons employed in the treatment
and processing of celluloid, on their engagement and at least every
three months thereafter. Further, he shall carry out a drill during
working hours, at least once every three months, with all persons

GERMANY

59

working on celluloid, and on this occasion, with reference to the
contents of the leaflet, speedy escape from workrooms in case of fire
shall be practised. The operation of fire extinguishers shall be entrusted
to specified persons.
11. Notification of Regulations
In every workroom and in the cloakroom, lavatories and rooms, a
legible printed copy of the leaflet for workers (section 10) shall be
posted up in a conspicuous place. Further, a copy of this Order and
of the latest text of the safety regulations shall be kept readily
. available and handed to the workers' representatives (Betriebsvertretung).
12. Exceptions
If adequate provision is made in an establishment for the safety
of the workers and the neighbourhood, the competent industrial
inspector may allow exceptions to the safety regulations, on request,
for a specified time and subject to revocation, on condition that such
exceptions are provided for by the Federal Celluloid Committee.
Authorisation of exceptions shall be in writing. It may be subject
to conditions. The employer shall post up a copy in the workrooms.
A further copy shall be transmitted to the competent State authority
which shall forward all such copies once every three months to the
Federal Celluloid Committee.
Before exceptions affecting the methods of working are authorised,
an opportunity shall be given to the workers' repiesentative body in
establishments where such exists and in other establishments to the
workers, to express their views.
13. Duty of Notification for Homework
Any person who causes celluloid articles to be treated or otherwise
prepared for sale or consignment by a homeworker shall, on the
commencement of the work, notify the competent factory inspector
of the homeworker's exact address and of any subsequent changes.
This provision shall not affect compulsory notification under
section 12 of the Homework Act.
14. Prohibited Processes in Homework
The issue of celluloid to homeworkers shall be prohibited if it must
be treated by:
(a) filing, scraping, drilling or any other process in which celluloid
waste is produced;
(b) warming or plasticising by artificial heat, except hot water;
(c) processes requiring the use of inflammable liquids.
Film lengths or film waste shall not be treated, processed, packed
or otherwise prepared.
The factory inspector may authorise exceptions to paragraph 1 if
the work is done in rooms not communicating with living rooms or
kitchens. Authorisation of exceptions shall be in writing and may be
subject to certain conditions.

60

LEGISLATIVE MEASURES

15. Special Safety Regulations
Homeworkers shall not have more than 5 kg. celluloid in the house
at any time.
Smoking shall be prohibited in the workrooms.
Kitchens shall not. be used as workrooms. The factory inspector
may authorise their use if only finished goods are prepared for sale or
consignment. Authorisation of exceptions shall be in writing and may
be subject to certain conditions.
16. Instruction of Homeworkers
The employer shall instruct the homeworkers in the dangers of
celluloid on first giving out work, and if further work is given at least
every three months thereafter. He shall hand over a copy of the leaflet
for homeworkers compiled by the Federal Celluloid Committee, and
also a notice "Smoking is strictly prohibited ". This notice shall be
posted up by the homeworker in a conspicuous place at the entrance
to his workroom.
At suitable intervals, and at least once every six. months, the
employer himself or a person appointed by him, shall verify that the
provisions of this Order are complied with.
17. Prohibition of Working
The processing of celluloid shall be prohibited in the workshop
of a homeworker who has twice been convicted of breaches of the
present Order.
18. Appointment of the Federal Celluloid Committee
For the compilation of the safety regulations and leaflets mentioned
in sections 7, 10 and 16, a Federal Celluloid Committee shall be set up.
It shall develop and amend the safety regulations in the light of
practical experience and scientific and technical discoveries; and, on
the request of the Federal Minister of Labour, express opinions on
questions affecting the safety of persons exposed to danger in the
treatment, processing, consignment or storage of celluloid, or on the
inclusion of any material among those mentioned in section 2 (paragraphs (1) and (2)). Decisions of the Federal Committee shall take
effect when promulgated in the Reichsarbeitsblatt by the Federal
Minister of Labour.
19. Composition
The Federal Celluloid Committee shall consist of fourteen regular
and fourteen substitute members, of whom the following shall be
appointed by the Federal Minister of Labour:
1 representative of the Federal Ministry of Labour;
1 representative of the Federal Insurance Office;
1 representative of the Federal Chemical and Technical Institute,
on the proposal of the Federal Minister of the Interior;
3 representatives of employers' associations;
3 representatives of trade unions.
In addition, the Federal Council (Reichsraf) shall nominate:
5 representatives of the social administrations of the Federal
States (Länder).

GERMANY

61

The members shall continue to hold office until their appointment
is revoked. Every change in membership shall be notified by the
Federal Minister of Labour to all regular and substitute members.
20. Procedure
The seat of the Committee shall be Berlin. The chair shall be taken
by the representative of the Federal Minister of Labour, who shall
have the casting vote. He shall convene the meetings of the Committee
and shall conduct the proceedings. The Committee shall draw up its
own standing orders.
The members shall act in an honorary capacity. No expenses shall
be borne by the Federal Government.
21. Advisers and Experts
The State Governments (Landesregierungen) not represented on the
Federal Committee for Celluloid by regular or substitute members shall
be invited to the meetings of the Committee. Their representatives
shall attend in an advisory capacity.
As permanently designated experts in an advisory capacity, shall
be invited to all meetings of the Committee, one representative of the
Association of German Factory Inspectors (Verein deutscher Gewerbeaufsichtsbeamten), one representative of the Federal Association of
German Fire-Prevention Engineers (Reichsverein deutscher Feuerwehringenieure) and one representative of the Central Office for Accident
Prevention attached to the Federation of Mutual Accident Insurance
Associations (Zentralstelle für Unfallverhütung beim Verbände der
deutschen Berufsgenossenschaften). Other experts may be called by
members of the Committee or otherwise, subject to prior approval
by the chairman.
For the study of particular subjects, the Committee may set up
sub-committees consisting of committee members assisted by experts.
22. Final Provisions
Sections 18 to 21 of the present Order shall come into force immediately, and the remaining sections six months after promulgation
of the Order.
On the coming into force of the present Order, the Order of the
Federal Minister of Labour of 4 May 1923 1 , concerning the processing
of celluloid by homeworkers (Reichsgesetzblatt, I, page 284), amended
by the Order of 29 June 19272 (Reichsgesetzblatt, I, page 137), shall cease
to be operative.
Building or safety regulations of the States (Länder) containing more
far-reaching provisions than the present Order or safety regulations
framed under the present Order, shall not be affected.
1
2

Reichsarbeitsblatt, 1923, p. 341.
Reichsarbeitsblatt, I, 1927, p. 328.

62

LEGISLATIVE MEASURES

Bules for the Protection of the Neighbourhood of Celluloid Undertakings
and Store-places. Dated 5 November 1932
A. PROTECTION AGAINST THE DANGERS ARISING FROM "WORKROOMS
AND STORE-PLACES IN BUILDINGS PARTLY USED FOR OTHER PURPOSES

1. Position in the Building
Workrooms within the meaning of section 1, paragraph (2) and
paragraph (3), sentence (2) and store-rooms within the meaning of
Part VII a of the Safety Regulations for Celluloid of 21 July 1931
shall not lie under rooms constantly occupied by persons. Sentence (1)
shall not apply if several floors of a building are used for plant for the
treatment and processing of celluloid, and these comply with the
provisions of section 11 of the safety regulations.
Paragraph (1) shall not apply to undertakings covered by the
Homework Act.
2. Distances from Other Buildings and Parts of Buildings
Openings in the outside walls of a celluloid workroom shall be at
least 12 metres (approximately) from the openings of opposite rooms
not belonging to the undertaking. If the parapet or the sill of the
openings of the celluloid workroom is higher than the lintel of the
openings of such opposite rooms, the general provisions of the building
regulations shall suffice.
Plant for working up celluloid film waste shall not be situated in
closely built-over localities. The manufacturing buildings shall be at a
distance of at least 20 metres from all other buildings. For the rest
the provisions, of section 48 of the safety regulations for celluloid shall
apply, mutatis mutandis.
If a neighbouring building or part of a building, has only one way
of escape and this is endangered by a plant for the treatment, processing
or storage of celluloid, more extensive requirements may be laid down.
B.

PROTECTION AGAINST DANGERS ARISING FROM BUILDINGS
EXCLUSIVELV USED FOR STORAGE

3. Distance
The storage buildings shall be at least 20 metres from public streets
and places and from non-fire-resisting parts of other buildings. If the
storage building holds not more than 4,000 kg. of celluloid, this distance
may be reduced to 12 metres.
A shorter distance may be allowed if:
(a) There is a rampart or fire-resisting safety wall in front of the
openings of the storage building; or,
(b) The walls facing the other buildings or public streets and places
are built as fire walls.
For storage buildings in the neighbourhood of buildings in which
large numbers of people regularly congregate (e.g. theatres, churches,
schools, department stores) or in the neighbourhood of plant in which
more than average fire risks must be reckoned upon, authorisation
may be refused unless adequate safety is ensured by more extensive
precautions.
The distances of celluloid film waste depots from neighbouring
buildings shall be subject to section 48 of the safety regulations.

GERMANY

63

C. STRUCTURE AND EQUIPMENT OF THE WORKROOMS AND STORE-PLACES

4. Application of the Safety Regulations
The corresponding provisions of the Safety Regulations for Celluloid
shall apply, mutatis mutandis, to the requirements to be laid down
for the structure and equipment of the workrooms and store-places in
so far as concerns the protection of the neighbourhood.
Safety Regulations for Celluloid of 21 July 1931 *
Edition of 5 November 1932.
PART I: GENERAL

1. Definitions
By "industrial plant " within the meaning of the Celluloid Order,
shall be meant all workrooms ana rooms directly connected with them
serving the purposes of the undertaking.
By "workroom " shall be meant any room in which celluloid in the
form of raw material, finished or half-finished articles, film or waste
is treated, processed or packed.
By "store-room" shall be meant any room in which celluloid is
stored otherwise than merely temporarily whether on completion of
the processing pending delivery to the purchaser or between two
processes separated by an interval of time. The temporary storage of
objects finished in the course of a shift pending conveyance to the
store-rooms shall not be deemed storage (see also section 57: subdepots).
PART I I : REGULATIONS ON THE POSITION, NATURE AND EQUIPMENT
OF WORKROOMS

2. Walls
The outside walls of the workrooms, and walls that separate
workrooms from ways of escape shall be fire-resisting2. Workroom
walls abutting on ways of escape shall be one brick thick or reinforced
with iron so as to withstand lateral pressure, and shall be securely
anchored in adjoining walls.
(esj
The walls of workrooms in which celluloid dust is given off shall
be washable up to a height of two metres.
3. Floors
The floors of the workrooms shall be easily washable and shall
have no open joins.
4. Windows
In every workroom in which the walls are not adequately secured
against lateral pressure (section 2) a window of at least 0.25 sq. metres
1
Compiled by the Federal Committee for Celluloid under section 7
of the
Celluloid Order of 20 October 1930 (Reichsgesetzblatt, I, p. 467).
a
Closer definitions of the terms "fire-resisting " (feuerbeständig),
and fire-obstructing (feuerhemmend) shall be left to the States (Länder)
so long as there is no uniform Federal regulation.

64

LEGISLATIVE MEASURES

clear area shall be so installed that it automatically opens at an inside
pressure not exceeding 6 kg. per sq. metre.
In every workroom an adequate number of windows shall have
easily accessible casements about 50 cm. wide and 75 cm. high and
easy to open. The windows shall not be fitted with grating, and shall
be filled in only with thin window glass without embedded wire.
5. Doors
Doors in walls that are required to be fire-resisting shall themselves
be fire-resisting and close automatically. In the case of doors leading
directly into the open both requirements may be dispensed with.
Celluloid workrooms shall have at least two doors, as far as possible
opposite, opening outwards and not diminishing the area of vestibules
or stair landings when open.
Both these doors shall, if not leading directly into the open, lead
to two vestibules or parts of vestibules or other means of escape
enclosed so as to be fire-resisting and separated from each other as far
as possible. For up to twenty employees the minimum clear width of
each door shall be 0.80 metres and for every further twenty employees
or fraction thereof, the aggregate width of the doors shall be increased
by 0.80 metres.
If fewer than five persons are employed in a workroom, it shall be
sufficient to have one exit leading into the open air or to a vestibule,
provided that the use to which the room is put ensures accessibility
of the door at all times.
6. Exits and Vestibules
The way from the workplace to the exit from the workroom shall
not exceed 20 metres.
Of the exits prescribed for a workroom at least one shall be not
more than 20 metres from the staircase or the exit leading into the
open.
Ways of escape from celluloid undertakings shall be si arranged
that they cannot endanger only ways of escape from rooms overhead
or on the same floor occupied by persons. For this reason direct
communication shall not be allowed with staircases leading from only
ways of escape from rooms overhead or on the same floor occupied
by persons.
7. Lighting
For lighting, only daylight or electric light shall be allowed. In
celluloid workrooms the lamps shall be enclosed in protective globes.
Portable light fittings shall be avoided as far as possible. Hand
lamps shall comply with the regulations in Appendix 1 (see also
section 9).
8. Heating
Hot-air heating by which several rooms are interconnected, and all
heating systems and drying equipment in which there may be open
fires, or in which radiators or heating pipes are liable to be heated
above approximately 115° C , shall be prohibited in celluloid workrooms. Tile stoves fired from a room in which no celluloid is present
shall be allowed.
All radiators and heating pipes shall be at least 15 cm. from the
floor, and so far from walls and ceilings that they can be easily cleaned.

65

GERMANY

Radiators in rooms, and heating pipes not covered in, shall be
protected, above and at the sides, against contact with celluloid or
other highly inflammable substances by means of wire mesh or perforated metal sheeting.
9. Electrical Equipment
Celluloid workrooms shall be deemed to be workrooms with special
fzre risks {feuergefährdet). The electrical light and power plant shall
comply with the special regulations in Appendix 1.
10. Fire-Extinguishing Plant
For every workroom at least two pails filled with water shall be
kept in readiness, and in rooms with a considerable number of workers,
one pail for every three workers. The pails shall be evenly distributed
over the room. Every pail shall hold at least 10 litres. If other suitable
fire-extinguishing plant is available, 1 e.g. hydrants with hoses, handextinguishers approved as utilisable , the prescribed number oi pails
may be reduced by half. On every floor at least one blanket difficult
to ignite shall be hung up within reach for saving burning persons.
In special circumstances more far-reaching requirements may be
prescribed.
11. Buildings with two or more Stories
More than one floor in a building shall only be used for plant in
which celluloid is treated, processed or stored when the floors are
separated from one another by fire-resisting means and each floor
used has at least one way of escape that in the event of a fire in the
celluloid rooms above or below cannot be endangered by smoke or
fire.
12. Celluloid Parts
In plant in which articles of other materials than celluloid are
regularly made with the addition of celluloid parts, the processing
of celluloid, so far as technically possible, shall be carried on in separate
workrooms.
PART I I I :

WORKING REGULATIONS

13. Prohibition of Smoking and Fire
In workrooms and in adjoining rooms presenting special fire risks
and directly communicating with the workrooms it shall be prohibited
to smoke or to use fire or bare lights. Matches and igniters shall not
be brought into the plant. This prohibition shall be notified by a
conspicuous and permanent notice.
14. Machining
When celluloid is being sawn, drilled or milled the piece of work
shall be cooled with running water so far as the nature of the operation
allows.
1

A survey of the fire-extinguishers tested and approved by the
Prussian Advisory Council for Fire Protection (Preussischer Feuerwehrbetraf) was published in the Reichsar be its blatt, No. 2, 1932, p. 117.
5

66

LEGISLATIVE MEASURES

15. Warming of Celluloid
For wanning celluloid, or heating presses only steam, hot water or
electricity shall be used.
The temperature of the heated apparatus parts shall not exceed
115° C. Electrical heating equipment shall be so made that celluloid
cannot come into contact with live, heated or incandescent parts, and
when the heated apparatus parts reach a temperature of 115° C. the
current is automatically switched off. With other heating apparatus
also the temperature must be effectively prevented from rising above
115° C.
16. Occupation of Workrooms
In each workroom there shall be at least 3 sq. metres floor space
and 12 cubic metres air space per worker. The maximum number of
workers allowable on this basis shall be indicated by a notice posted up.
17. Arrangement of Passage-Ways
The workplaces shall be so arranged that the passage-ways leading
to the exits shall be at least 1.20 metres wide. The passage-ways shall
always be kept clear.
18. Maximum Quantities of Celluloid
At any workplace there shall be only so much celluloid in any form,
including raw material for processing, as is necessary for the continuance of the work. Quantities in excess of this shall be stored in
store-rooms or the sub-depot (Betriebszwischenlager).
19. Waste
Fine waste (shavings, sawdust) shall be collected directly at the
workplaces, as far as possible in containers filled with water and capable of being closed immediately with a lid in an emergency oi when
not in use. Larger quantities of waste shall only be kept in containers
with tight-fitting lids. The waste shall be placed at least once during
every shift in a storage receptacle installed outside the workrooms
or in a waste depot. The storage receptacle shall be emptied at least
twice a week. Waste shall not be burnt in closed fires.
20. Cleaning
The workrooms shall be swept every day and thoroughly cleaned
at least once a week. The workplaces shall be cleaned every day.
In cleaning work in which there is a risk of ignition of celluloid,
celluloid dust or inflammable liquids, use shall only be made of tools
of wood, copper, brass, etc., which do not spark.
21. Repairs
Repair or similar work in which there is a danger of sparking owing
to the tools used or electrically-driven apparatus or other reasons, or
in which fire must be used, shall only be undertaken after all the
celluloid has been removed within a radius of at least 5 metí es of the
workplace, and then only under responsible supervision. Any exhaust
plant shall be blown through. Care shall be taken to secure a good
inflow of fresh air.

GERMANY

67

22. Inflammable Liquids
Inflammable adhesives and solvents (amyl acetate, butyl acetate,
acetone, alcohol, etc.) and paints containing such substances, shall
be kept at the workplaces only in such quantitites as are necessary for
the continuance of the work and in no case in excess of the requirements
of one shift. Such substances shall not be given out to the workers in
the workrooms.
Stocks of inflammable liquids shall not be kept in celluloid storerooms. 1
23. Removal of Vapours
Work in which vapours of inflammable or noxious liquids are given
off shall be done in special rooms. These shall have ventilation openings
under the ceiling and directly above the floor.
24. Exhaustion
If celluloid articles are coated with paints that contain inflammable
or noxious solvents, especially by spraying, the fumes or vapours of the
solvents shall be so collected and exhausted where they arise that they
cannot spread into the workroom.
The exhausted air shall be led off into the open by the shortest
way and not in chimneys or so as to pass near fireplaces. The piping
shall be earthed.
In spraying plant the fresh air for the compressor shall not be taken
from the workroom.
25. Small Containers
The bottles for the workers' immediate use on the workbench or
for filling the spraying pistol shall as far possible be kept closed and
secured against falling over. They shall be labelled "Inflammable ".
26, Special Regulations
Where there are special regulations for lacquer spraying plant,
these shall be applied in conjunction with the provisions of Sections 22
to 25.
27. Employment of Juvenile Workers
The employment of juvenile workers under eighteen years of age
shall be allowed in the manufacture, finishing, shaping, trimming and
packing of celluloid goods. It shall be prohibited on work with machines
on which celluloid can become dangerously heated (e.g. circular saws,
circular rasps and straight rasps), or on the soldering of metal receptacles containing celluloid, or on work in which celluloid dust or fine
celluloid waste (shavings, sawdust) is given off in any quantity, or
inflammable liquids are used in any quantity.
The restrictions in paragraph (1) shall not apply to the employment
of individual juvenile workers under the permanent supervision of
adults.
In the gumming of films, girls between sixteen and eighteen years
of age may be employed as learners. There shall not be more than one
girl under eighteen years of age for every five adults.
1
Storage is regulated by the provisions of the police regulations
on the handling of inflammable liquids.

68

LEGISLATIVE MEASURES

PART IV:
SPECIAL REGULATIONS FOR UNDERTAKINGS IN WHICH
CELLULOID FILM BASES ARE COATED WITH A LIGHT-SENSITIVE
LAYER

28. General
The provisions of Sections: 1 to 3; 5 to 9; 10, sentence (5) and
paragraph (2); 11; 13; 16 to 19; 20, paragraph (2); 21; 22 and 25
shall apply.
29. Protection of Machinery
In artificially darkened rooms machines and other equipment shall
be provided with safety devices that ensure a sufficient degree of
safety notwithstanding the increased risk.
30. Light Locks
Doors in light locks shall open outwards or be swing doors. The
clear width of the doors shall be regulated by the provisions of
section 5.
The interlocking of the doors of a light lock to allow the opening
of only one door at a time shall not be authorised in workrooms in
which more than five workers are employed unless in an emergency the
interlocking can be disconnected by a simple manual operation.
In new buildings, light locks shall be open (constructed as labyrinths) and lead to a special corridor allowing easy escape into the open.
Neither in the light lock nor in the dark parts of the corriaors shall
there be steps or thresholds.
31. Emergency

Lighting

In darkened workrooms in which more than twenty persons are
employed, independently of the general lighting there shall be installed
emergency lighting lighting up, inter alia, the corridors and exits, the
position of the flame-proof blankets and other emergency apparatus.
In darkened workrooms occupied by persons only during the
daytime, the special emergency lighting may be dispensed with if the
presence of windows enables the room to be lighted at all times.
32. Lighting in Emergencies
In every darkened workroom in which more than twenty persons
are employed, bright lighting shall be provided which can be switched
on in an emergency or panic. The switches shall be indicated by a
notice "Switch on in emergency ", and may be protected against
careless actuation. Bright lighting shall not be required when in an
emergency at least one window or one door leading into the open can
be quickly opened by a simple manual operation.
33. Ventilation
In every darkened workroom adequate renewal of the air shall be
ensured by means of a suitable ventilating device.
In rooms in which complete renewal of the air at least three times
an hour is ensured, the air space for the workers as specified in section 16
may be reduced to 9 cubic metres.

69

GERMANY

PART

V:

SPECIAL REGULATIONS

FOR CINEMATOGRAPH

FILMS

34. Definition
By "treatment " shall be meant all processes to which the film is
subjected between exposure and delivery to the user, including cleaning, touching up and lacquering.
35. Workrooms
Workrooms in which films are treated shall comply with the provisions of sections 2-11.
36. Treatment of Unprotected Films
For workrooms in which unprotected films are treated, the provisions of sections 13, 16-22 and 25 shall apply, mutatis mutandis.
As a rule, not more than four persons shall be employed in any one
gumming room. If for special technical reasons this number has to be
exceeded, up to 25 persons may be employed, on condition that the
position and number of the exits ensure particularly easy egress from
the workrooms and devices are provided on every workbench that
prevent the immediate spread of a fire to neighbouring workbenches.
Not more than two persons shall be employed at any one workbench.
Admittance to workrooms of unauthorised persons shall be prohibited by notice.
It shall be prohibited to bring films, even temporarily, into rooms
not assigned for their treatment or storage (e.g. offices, store-rooms for
printed matter) This provision shall not apply to temporary exhibiting
of small samples.
In workrooms, work other than that for which the rooms are
intended shall not be done.
37. Workbenches
Workbenches on which films are tested, assembled or stuck together
by artificial light shall be illuminated only by electric light. If the
source of light is under the film, only lamps not exceeding 15 watts
shall be allowed. The viewing frame shall be made dustproof.
38. Winding Mechanism
In order to prevent dangerous heating of the film during winding,
the supporting surface on the unwinding side ot the workbench shall
be covered with metal, unless turntables or similar devices are used.
The pin of the winding mechanism shall be of metal.
39. Wet-Process Rooms
For rooms in which films are treated wet (developed, fixed, etc.),
exceptions may be allowed. When such rooms are darkened the
provisions of sections 4 and 7 may be correspondingly altered.
40. Projectors
Only projectors complying with the regulations for projectors in
cinematograph theatres shall be employed.

70

LEGISLATIVE MEASURES

41. Operators' Boxes
In copying undertakings projectors used not tor the showing of
films before spectators but only for the supervision of the process may
be installed in the workrooms themselves when such rooms comply
with the provisions of sections 2-11. Only apparatus in class B or C
shall be used as projectors.
In copying, distributing, etc., undertakings the projectors used for
the showing of films before spectators shall be installed in separate
rooms. As regards outside walls, floors and doors, these rooms shall
comply with the requirements of sections 2, 3 and 5. For the rest, the
following provisions shall apply:
Operators' boxes in distributing, etc., undertakings shall have no
communication with the auditorium or the other workrooms. Operators' boxes in copying undertakings shall communicate with the
auditorium only by an opening measuring not moie than 30 x30 cm.
It shall be closed by an iron shutter at least 2 mm. thick, running
easily and surely in guides so that it cannot jam or work out. The
shutter shall close automatically and instantaneously in the event of a
fire, and also be workable b y hand.
The exit from the operator's box shall lead directly into the open.
If this is not possible, it shall so lie as to lead through a room or vestibule
not exposed to risk. If use has to be made of a vestibule, staircase or
way of escape used by persons not belonging to the undertaking, the
exit from the operator's box shall be constructed as a safety lock
(Sicherheitsschleuse).
If exits from the operator's box lead over stairs, these shall be at
least 65 cm. wide and provided with at least one handrail. Ladders
and spiral stairs shall be prohibited in operators' boxes.
A ventilation opening at least 0.25 sq. metres in area shall lead
directly into the open oi into a fire-resisting air shaft open at the top
and not communicating with other rooms. The shutter of this opening
shall have no bolts. In the event of afire it shallbe opened automatically
by the pressure generated, except when an exit from the operator's box
leads directly into the open.
For a minimum length of 2 metres the room for the installation of
the projector shall have a clear height of at least 2.80 metres, and a
floor space of at least 6 sq. metres. For every additional projector
installed the prescribed minimum floor space shall be increased by at
least 2 sq. metres.
The observation ports shall not measure more than 250 sq. cm.
The light ports shall not be larger than required to allow the passage
of the beam of light. Both sets of openings shall be closed smoketight by means of glass plates at least 5 mm. thick.
The operator's box shall contain only such electrical switchgear
as is required for operating the projector and lighting the auditorium.
All electrical equipment and heating equipment shall be placed so high
or be so covered that objects cannot be laid upon it.
In the operator's box there shall be only the films required for the
projection in course, and in any case not more than 25 kg. These shall
be kept in a special container of hard wood or other material affording
equivalent protection against heat. The container shall be divided by
vertical partitions into compartments holding only one film reel each
and closing automatically. The container shall be installed as far as
possible from the projector and the exits.

GERMANY

71

Not more than 30 grm. of highly inflammable adhesives shall be
present.
The winding mechanism shall be placed as far as possible from the
projector.
A pail always filled with water and a blanket of low inflammability
shall be kept in readiness for saving burning persons.
42. Operator
Any person entrusted with the single-handed operation of a projector shall possess an operator's certifícate issued by the competent
operators' testing authority, or approved by the highest State
authority '.
The provisions of paragraph 1 shall come into force one year after
the promulgation of the safety regulations.
PAKT VI:

WORKING-UP OF CELLULOID F I L M WASTE

43. Working-up Processes
The coating of emulsion shall be removed from unutilisable films
or film waste only by processes in which heating of the films such
as to cause decomposition or ignition cannot occur and in which the
chemical properties of the film are not changed.
44. Structural Arrangements and Distances
The plants shall comply with the provisions of Part II and, mutatis
mutandis, with those of Part III. For the rest, the following provisions
shall apply:
The manufacturing buildings shall be at least 20 metres from one
another. This distance may be reduced to 10 metres when one of any
two opposite building fronts is built as a blank fire-resisting wall.
Workrooms and store-rooms shall be situated only in one-storied
buildings. As an exception workrooms may be allowed in existing
buildings of several stories provided that they are situated on the
ground floor, and the basement and the floors above are permanently
so separated off that they cannot be entered.
Every workroom shall have at least two exits leading directly
into the open from different sides. In rooms in which there is loose
waste no workplace shall be more than 6 metres from the nearest exit.
At least one exit in every room shall be so situated that it cannot
be endangered in the event of a fire in any of the neighbouring buildings
in which celluloid is handled or stored.
At least half the exits shall be on the side of the building away from
the plant, store-place.
AH windows shall be so installed that they can be immediately used
as ways of escape.
45. Shredding of Waste
As far as possible waste shall only be shredded wet. Shredding
machines shall be so installed and driven that ignition is prevented.
Each machine shall be installed by itself in a separate room.
1
Cf. the various State regulations on principles for safety in cinematograph performances, issued in connection with the Circular of the
Federal Minister of the Interior, No. Ill, 9157, of 6 November 1925.

72

LEGISLATIVE MEASURES

46. Drying of Waste
Waste shall be dried only at a temperature not exceeding 45° C.
The maintenance of this temperature shall be permanently controlled
by indicators. Higher temperatures shall be prevented by reliable
devices. Drying plant shall be heated only by air that is itself heated
by hot water or low-pressure steam apparatus, or in heating systems
in which it cannot come into contact with heating pipes directly
played upon by fire.
The radiators and the entire drying plant shall always be thoroughly
cleansed after being emptied, and at least once a day, the latter
especially from film waste and dust.
In drying rooms work not directly connected with drying shall
be prohibited.
47. Packing and Transport
Washed films shall only be packed in rooms separated off by fireresisting means from the other workrooms and store-rooms.
Without prejudice to the provisions of Part IX, waste shall be
packed only in undamaged and closely woven sacks and transported
only in closed vehicles or open vehicles in which it is completely
covered by an impervious tarpaulin.
48. Store-places for Celluloid Film Waste
The structural arrangements of the store-places shall comply with
the general provisions of Part VII. As a rule films and film waste
shall only be stored packed (cases, drums or closely-woven sacks).
Storage buildings housing more than 4,000 kg. shall comply with
the following additional provisions:
They shall be at least 50 metres from all manufacturing buildings
constantly occupied by persons. This distance may be reduced if the
neighbouring buildings are protected by fire walls or a rampart. Not
more, than 20,000 kg. of waste shall be stored in any one room. Two
or more immediately adjoining store-rooms shall be separated from one
another by blank walls at least one brick thick.
The roofs of the storage buildings shall be so lightly constructed
that they yield to pressure before the outside walls.
In specially favourable local circumstances, and as an exception,
up to 20,000 kg. of waste may be stored in sheds satisfying the regulations and having metal-faced outside walls, if the ground outside the
storage building is kept free from combustible objects on all sides for a
distance of 10 metres and is so treated that grass fires cannot break
out within this distance. The access of unauthorised persons to such
storage buildings including the prohibited zone shall be prevented by
fencing.
Care shall be taken by suitable measures that the stocks of unwashed
films shall as far as possible be worked up in the order in which they
were placed in storage.
PART VII:

REGULATIONS FOR CELLULOID DEPOTS

(a) Depots in Buildings partly used for Other Purposes.
49. Position of the Store-room
No form of celluloid shall be stored underneath rooms constantly
occupied by persons.

GERMANY

73

For existing buildings exceptions may be allowed if the ways oi
escape from the floors overhead are not endangered.
50. Maximum Quantities
Not more than 4,000 kg. of celluloid shall be stored in any one
store-room.
The quantity of undeveloped cinematograph film storable in any
one room may be raised to 10,000 kg. if all the film is packed as required
by transport regulations.
In general the above-mentioned quantities for storage may be
increased when local conditions or special precautions appear to
preclude any danger to persons.
Several store-rooms holding not more than 4,000 kg. each may be
allowed in one building, when their construction and relative positions
ensure that a fire in one cannot endanger another.
51. Distances from Other Buildings
The openings of store-rooms shall be at least 12 metres from opposite
buildings or adjoining buildings or parts of buildings forming an angle
of less than 90° if the openings in such buildings or parts of buildings
are more than 3 metres higher.
52. Walls, Ceilings and Floors
The outs'de walls of the store-room shall be fire-resisting and at
least 25 cm. thick, or consist of fire-resisting double walls separated by
an air space. In the latter case the inner wall shall also be reinforced
with iron and shall be securely anchored in the adjoining walls.
Chimneys shall not have openings in the room. The sides of
chimneys towards the room shall be so constructed as to preclude any
heating likely to endanger the stock of celluloid.
The ceiling of the store-room shall be fire-resisting. In top stories
the ceiling may be formed by an unprotected roof when the separation
from neighbouring rooms is such as to ensure that propagation of a
fire from these rooms to the store-room or vice versa is as far as possible
prevented. In the store-room projecting wooden parts of the roofing
shall be encased by at least fire-obstructing materials.
The floor of the store-room shall be incombustible unless the ceiling
of the room underneath is fire-resisting.
53. Doors and Windows
The doors of the store-room shall be fire-resisting, open outwards
and close automatically. On the outside shall be affixed a notice
"Celluloid depot: no admittance to unauthorised persons". Doors
leading directly into the open need not be fire-resisting if the requirement laid down in section 51 is satisfied.
The store-room shall be provided with at least one window giving
on to the open, or at least one vent with a total cross section equalling
5 per cent, of the floor space. Windows shall be regulated by the
provisions of section 4, paragraph 2 and shall be permanently dimmed
as a protection against the sun's rays.

74

LEGISLATIVE

MEASURES

54. Exits
Every store-room shall have an exit separated off by a fire-resisting
door. In special cases two exits may be required.
The way of escape shall be enclosed in at least fire-obstructing walls
and ceilings.
Between the store-room and the staircase there shall be two fireresisting doors, one behind the other. In the case of store-rooms for
undeveloped cinematograph film and packed celluloid goods, the
factory inspector may allow the second door to be dispensed with.
55. Prohibition of the Storage of Other Materials
Other highly inflammable materials shall not be kept in the storerooms.
56. Work in Store-rooms
In store-rooms no work shall be done other than that required for
storage purposes.
57. Sub-depots
By " sub-depots " (Betriebszwischenlager) shall be understood rooms
serving for the storage of quantities of celluloid that under section 18
must be removed from the workplaces but are still in process of
manufacture. For these rooms the provisions governing workrooms
shall apply.
58. Lighting, Heating, Prohibition of Smoking
The provisions of sections 7-9 and 13 shall apply, but tiled stoves
shall not be allowed.
59. Exceptions
The provisions of sections 49-58 shall not apply to the storage of
amateur films (roll, pack and miniature films), and sheet films (X-ray,
portrait, and technical films and films for aerial photography) in
ordinary retail packing.
(b) Depots in Buildings exclusively used for Storage
60. Quantities storable
Not more than 20,000 kg. may be stored in any one store-room.
This quantity may be increased to 100,000 kg. including packing in the
case of unexposed cinematograph film packed in compliance with
railway transport regulations. Two or more store-rooms shall be
separated from one another by blank fire walls. Section 51 shall apply.
61. Number of Stories
As a rule storage buildings shall be one-storied; as an exception
two stories may be allowed if the requirements of section 11 are
satisfied. In this case the basement shall be reckoned as one story.
Only one story may have openings in any one outside wall.
62. Outside Walls
Section 52, paragraph (1) shall
separation of store-rooms shall have
at least 0.5 metres above the roof
resisting ceilings without openings.

and Fire Walls
apply. Inside fire walls for the
no opening. They shall be carried
unless the store-rooms have fire-

GERMANY

75

As an exception metal-faced outside walls may be allowed for onestoried storage buildings. In such buildings any inside fire walls
shall be carried to at least 0.5 metres above the roof and at least 25 cm.
beyond the outside walls. The metal facing shall be so lined as to
protect the store-rooms against heat of the sun's rays.
63. Exits
Each store-room, even in two-storied buildings, shall have at
least one exit leading directly into the open.
64. Other Provisions
The provisions of section 52, paragraph (2), section 53 (apart from
the requirement as to self-closing and fire-resisting doors), and
sections 55, 56, 58 and 59 shall apply.
PART V I I I : SHOPS

65. Shops
Without prejudice to any special provisions for warehouses, etc.,
in the salesrooms of shops shall be kept only celluloid articles directly
for sale. Further quantities of celluloid articles shall be stored in
special rooms to which the provisions of Part VII shall apply. The
celluloid articles kept ready at hand in the salesrooms shall be at a
sufficient distance from stoves, bare lights, and highly inflammable
substances (e.g. benzine, ether, fireworks).
The provisions of paragraph (1) shall not apply to amateur films
(roll, pack and miniature films), and sheet films (X-ray, portrait and
technical films, and films for aerial photography) in ordinary retail
packing.
PART IX: REGULATIONS FOR PACKING AND CONSIGNMENT

66. Packing Cases
For the packing of celluloid, celluloid articles and celluloid waste
for the purposes of consignment, the provisions of the Railway Transport Order, the Maritime Freight Order and the Post Order shall
respectively apply 1 .
67. Metal Containers
If celluloid is packed for consignment in metal containers that have
to be soldered, the soldering shall only be done outside the workrooms.
The contents of the containers shall be covered with a poor conductor
of heat. The soldering shall be done only by specially trained and
reliable workers.
1
(1) Appendix C to the Railway Traffic Order of 16 May 1928,
edition of 1 July 1931, printed in Supplement VIII to the German
Railway Goods Tariff, Part 1(a).
(2) Maritime Freight Order compiled by agreement between the
Maritime States (issued, e.g. in Prussia, as police regulations of the
Minister of Commerce and Industry, dated 18 September 1930,
Ministerialblatt der Handels- und Gewerbeverwaltung, p. 239).
(3) Post Order of 30 January 1929 {Reichsgesetzblatt, I, p. 33),
section 5, paragraph IV.

76

LEGISLATIVE MEASURES

68. Prohibition of Smoking
Smoking shall also be prohibited to workers employed in packing
outside the workrooms.
PART X :

REGULATIONS FOR HOMEWORK

69. Scope of Special Regulations
The rooms of homeworkers for whom the Factory Inspectorate has
authorised exceptions under section 14, paragraph (3), of the Order
shall be governed, mutatis mutandis, by the provisions of sections 2-27.
For other rooms, the said provisions shall be replaced by the provisions
of this Part.
70. Workrooms
Celluloid shall only be processed in rooms from which in an emergency the persons employed can escape quickly. If several rooms are
interconnected, the room in which the celluloid is processed shall not
so lie that in an emergency the way of escape from the other rooms is
cut off. Rooms on the ground floor are safest.
71. Storage
On the workbench there shall be only as much celluloid as is
required for the continuance of the work. The rest of the stock, as well
as the finished articles, shall be kept in solid boxes or in closed cupboards. The store-place shall not lie near a bare light, a heated stove,
or an exit.
72. Workplace
The workplace shall not be in the immediate vicinity of stoves or
bare flames.
73. Lighting
In houses in which there is electric light this shall be used for the
workrooms of homeworkers. The lamps shall be enclosed in outer globes.
If gas or paraffin has to be used, only suspended lamps with incombustible suspensions shall be used. The source of light shall be at least
1 metre above the workbench; and underneath it shall be placed a
metal container to catch any escaping paraffin, falling sparks, hot
lamp parts, etc.
74. Protection against Fire, Prohibition of Smoking
There shall be no smoking in the workrooms, even by visitors. A
notice shall be affixed with the wording " Smoking strictly prohibited ".
In addition to a pail always filled with water there shall be kept in
readiness a wet cloth with which any celluloid that may catch alight
can be safely thrown into the water.
75. Prohibition of Spraying
The decoration of celluloid by spraying shall be prohibited except
in rooms communicating neither with living rooms nor kitchens.
76. Cleaning
The workrooms and workplaces shall be swabbed daily after the
close of work.

GERMANY

PART X I :

77

EXCEPTIONS

77. Exceptions
The competent factory inspector shall be empowered to authorise
exceptions to individual provisions subject to revocation, provided that
adequate precautions are taken for the workers' safety.
Such exceptions shall not be allowed to the provisions of section 2,
paragraph (1), sentence (1), concerning the fire-resisting properties of
the walls, of section 4, paragraph (2), section 6, paragraph (3), and
sections 9 and 10; of section 11 as regards the way of escape; of
sections 13, 17-27, 31-33, 36, 40-48, 52, 53, 54, paragraph (1), and
sections 55-76.
If compliance with the provisions of paragraph (2) is fraught with
undue difficulties in a particular case, subject to the previous authorisation of the building inspection and fire inspection authorities, and
after consultation with the competent mutual accident insurance
association (Berufsgenossenschaft), the competent factory inspector
may also allow revocable exceptions to these provisions.
78. Alternative Arrangements
When, owing to lack of space, the provision of a cloakroom
complying with the provisions of section 9, sentence (2), of the Order
is not feasible, then under sentence (3) alternative arrangements may
be allowed if the employer shows that at his own expense he has
insured the workers' clothing for an appropriate amount against fire.
He shall notify this in the course of fire drills and by means of notices
posted up in the workrooms.
APPENDIX 1
(Under sections 7 and 9 of the Order)
Regulations for Electrical Equipment and Appliances 1
A. — Electrical Equipment in Workshops with Special Fire Risks
1. Electric machines, transformers and resistances, as well as
switches, fuses, plugs and similar apparatus in which in ordinary working
the current is interrupted or heating occurs, shall only be used when
by their construction or by other suitable measures the inflammable
materials are prevented from coming into contact with dangerous parts.
(a) By "suitable measures " shall be understood an arrangement
by which the penetration of foreign bodies to bare, live or
revolving parts is hampered. Complete protection against dust,
damp or the presence of gas in the air is not prescribed, and in
the case of motors the inflow of cool air from the surrounding
space shall not be prevented. In the case of motors with a shortcircuited rotor (squirrel-cage rotor), an open construction shall
suffice. In the case of resistances, switches, fuses, plugs and
similar apparatus, all parts without essential openings shall be
completely enclosed.
(b) In all cases the use of motors with short-circuited rotors shall
be recommended in three-phase-current plant.
1
Taken from the regulations of the Association of German Electrical
Engineers (Vorschriften des Verbandes Deutscher Elektrotechniker).

78

LEGISLATIVE MEASURES

2. Bare wires shall not be allowed. Insulated wires shall be laid
in conduits or as lead cable or as cable-like wiring.
(a) Special attention shall be devoted to protection against mechanical damage.
(6) Filament lamps near inflammable substances shall be provided
with fittings preventing contact between the lamp and such
substances.
B. — Electric Hand Lamps
1. The fittings and handles of electric hand lamps shall be made of
insulating material capable of withstanding the wear to which it is
exposed in use. Metal lining on handles shall be prohibited.
2. Hand lamps shall be so constructed that the junctions of the
wiring are secured against strain, the sheathing of the wiring against
wear, and the strands of wire against twisting.
3. The points of entry of the wiring shall be so arranged that there
is no fear of damage to the flexible wires, even with rough handling.
It shall be possible to use workshop cords and cab-tyre cables of
medium size.
4. Key holders on hand lamps shall be prohibited; but keys for not
more than 250 volts and not less than 6 ampères shall be allowed. Such
keys shall be installed as quick-break switches, and so built into the
fittings or handle as to be secure from mechanical damage. Their
controls (Betätigungsteil) shall not be live.
5. Every hand lamp, according to its use, shall be provided with
a wire guard or an outer globe, or with both. Metal protective casing,
wire guards, reflectors, suspension hooks, supporting straps, etc., shall
he mounted on the insulating fittings; protective casing, wire guards,
etc., shall be so fastened to the fittings that they do not automatically
work loose.
6. Hand lamps shall have devices preventing the penetration of
damp to the points of entry of the wiring, and also injury to the wiring.
APPENDIX 2
(Under section 10 of the Order)
Leaflet for Celluloid Workers
1. Celluloid is extremely inflammable. It burns extraordinarily
quickly and with great heat. If warmed it often flares up suddenly
and forms long, hot sheets of flame. When undergoing nameless decomposition it gives off voluminous clouds of poisonous fumes which are
themselves inflammable and may cause an explosion.
The utmost caution is therefore necessary.
2. Celluloid should never be brought into contact with bare flames,
hot parts of stoves, piping, etc., or stored or processed near them.
Hence in all workrooms and store-rooms it is prohibited to smoke, to
use matches or igniters, and likewise to use tools or appliances that
may give off sparks (abrasive wheels, etc.).
3. If celluloid catches alight or if in the processing local overheating
accompanied by smoke occurs, water should immediately be poured
over the danger spot. If the fire cannot be extinguished at once, there
is only one salvation — escape from the workroom !
4. In drilling, milling and sawing celluloid by machine the tool
and piece of work should be cooled by running water. Waste should
be steeped in an iron vessel filled with water. Any excessive heating
of celluloid should be avoided.
5. Fire buckets in the workrooms must always be filled with water.
6. If your clothing catches alight roll on the ground to smother
the flames. Running feeds the flames. Help your burning comrade.

GERMANY

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Try at once to smother the flames with the fire blanket kept in the
workroom.
7. All ways to the exits, and all ways of escape, must be kept clear.
Make sure in good time, i.e. before an accident occurs, which is your
quickest and safest way of escape.
8. And however strong your craving to smoke, remember that a
dropped match may cost you and your comrades your lives.
APPENDIX 3
(Under section 14 of the Order)
Leaflet for Homework with Celluloid
1. Celluloid is extremely inflammable. It burns extraordinarily
quickly and with great heat. If warmed it often flares up suddenly
and forms long, hot sheets of flame. When undergoing flameless decomposition it gives off voluminous clouds of poisonous fumes which are
themselves inflammable and may cause an explosion.
The utmost caution is therefore necessary. Celluloid should never
be stored or processed near a hot oven or open fire.
2. Particularly dangerous is the treatment of celluloid by:
(a) filing, scraping, drilling, or other processes in which celluloid
waste is produced;
(ft) warming, except when hot water is used for the purpose;
(c) processes involving the use of inflammable liquids.
Hence such processes are prohibited. Only for a special workroom
separated from the living room or kitchen can the factory inspector
authorise them, and only in writing.
Lengths of film or film waste must not be treated, packed or otherwise prepared.
3. Work must not be done in kitchens. Only when finished articles
have to be prepared (e.g. mounting or sewing buttons on cards) can the
factory inspector, by way of exception and in writing, authorise the use
of kitchens.
4. Working in the immediate vicinity of stoves or bare flames is
dangerous. It is useful to fasten to the worktable, in front of your
seat, a piece of stuff in the form of a sack to catch any falling pieces
of work.
5. Be careful with artificial lighting. Electric light is safest. Gas
or paraffin should only be used in suspended lamps with incombustible
suspensions. Such lamps should hang at least 1 metre above the workbench, and under them should be placed a metal container to catch
escaping paraffin, falling sparks, hot lamp parts, etc. Paraffin lamps
should be lighted outside the workroom. For gas flames special igniters
(platinum sponge or friction igniters) should be used.
6. Never smoke in rooms in which celluloid is stored or processed.
Also make visitors refrain from smoking. The use of matches or bare
lights is prohibited. A dropped match may cost you and your family
your lives, or all your possessions.
Outside the door a notice must be affixed with the wording "Smoking
is strictly prohibited ".
7. Celluloid, finished articles and waste must not be kept in the
house to a total amount of more than 5 kg.
8. After the close of the day's work the workrooms and workplaces
must be swabbed out.
9. A pail filled with water and by it a cloth for extinguishing fires
must always be kept in readiness in the workroom. Quickly throw
burning pieces of celluloid into the pail with the wet cloth, and take
the pail at once into the open. A small fire can sometimes be put out

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LEGISLATIVE MEASURES

with plenty of water. If this cannot be done at once there is only one
salvation •— escape from the workroom. The nearest fire station must
be immediately called.
Model Safety Regulations for the Use and Storage of X-Ray Films in
Public Health and Welfare Institutions
PART

I : RANGE OF APPLICATION OF THE

SAFETY

REGULATIONS

1. Scope
The following safety regulations shall apply to the use and storage
of X-ray celluloid films in all official, voluntary and private publichealth and welfare institutions.
Such institutions shall be deemed to include in particular:
in the sphere of indoor assistance: general hospitals, specialist
medical institutions and maternity homes;
in the sphere of semi-outdoor assistance: day institutions for cases
or potential cases of sickness;
in the sphere of outdoor assistance: consulting centres, welfare
centres, polyclinics, dispensaries and treatment centres;
establishments of doctors with a private practice, dentists and
veterinary surgeons, and of members of other curative professions ;
laboratories.
The corresponding activities shall be assimilated to the establishments.
2. Exceptions
The safety regulations shall not apply when only safety X-ray
films are used and stored.
Safety X-ray films shall be held to be films that bear on the
wrapping, and indelibly on every film, the m a r k " DIN Sicherheitsfilm "
(DIN safety film). This mark shall only be borne by films of which a
piece 20 cm. long and 3.5 cm. broad, when held horizontally on edqe
and ignited at a bottom corner with a match flame, either does not
continue to burn when the flame is removed, or takes more than
60 seconds to burn completely.
X-ray films without this mark shall be deemed to be safety X-ray
films if they satisfy the requirements of paragraph 2 above in the
ignition test.
PART I I :

SAFETY REGULATIONS

3. General Provisions
(a) X-ray films shall not lie about loose indefinitely. They shall in
no case be stored permanently in the sick-rooms themselves, even if kept
in wrappings or in the special containers for the purpose.
(6) The persons employed in the establishments shall have their
attention drawn at least once a year to the dangers involved in handling
films and shall be instructed that, after use, films should always be
kept in the storage containers specially provided for the purpose
(e.g. hard-wood boxes or safes) and that these must be kept closed.

81

GERMANY

(c) In all store-rooms for X-ray celluloid films a leaflet on the
handling and storage of such films shall be posted up (Appendix 1).
Further, a copy of the present safety regulations shall be kept readily
available on the premises and handed to the workers' representatives
(Betriebsvertretung).
(d) In all rooms in which developed films are stored, smoking shall
be prohibited. Attention shall be drawn to this prohibition, in a
conspicuous manner, by means of posters outside the entrance doors
and inside the rooms.
(e) At the entrance doors of film depots (section 4, 16 and II) the
following notice shall be posted up both outside and inside :
FILM DEPOT
Always Shut the Door.
Smoking and Entering with Bare Lights Prohibited.
(/) Bare flames shall not be permitted in rooms in which there is
more than 5 kg. of developed film.
(g) In the immediate vicinity of every depot holding more than
5 kg. of film, a water or foam extinguisher approved as utilisable shall
be installed.
(h) Cast-away and unutilisable X-ray films shall be handled in
establishments in the same way as all other X-ray films, removed to a
collecting centre at suitable intervals, properly stored, and suitably
disposed of, e.g. to dealers. Destruction of unutilisable films in the
establishment itself shall be prohibited.
4. Special Provisions
I. — Storage of X-ray films to an amount not exceeding 150 kg. net
weight per room, in, by, over or under rooms permanently occupied
by persons, or in rooms communicating with such rooms.
(a) Storage of films to an amount not exceeding 10 kg. or 5 kg. net
weight respectively in main rooms1 (consulting rooms, sick-wards,
laboratories, etc.).
Not more than 10 kg. net weight (i.e. about 52 dozen films
18x24 cm., or 18 dozen 30x40 cm.) of unexposed film shall be stored
in any one room in the original packing. The films shall be stored
at least 1 metre from radiators or fireplaces.
Not more than 5 kg. net weight (i.e. about 308 films 18x24 cm.
or 110 films 30x40 cm.) of developed films shall be present in any one
room. For storage, use shall be made of a container closed on all sides
and installed at least one metre from radiators or fireplaces. It shall
suffice if such containers are of hard wood, or other material that is
an equally poor conductor of heat and equally difficult to ignite.
(b) Storage and quantities of film from 10 kg. or 5 kg. respectively
up to 150 kg. net weight per room (sub-archives).
Quantities of unexposed films between 10 and 150 kg. net weight,
and quantities of developed films between 5 and 150 kg. net weight
(i.e. about 9,240 films 18x24 cm., or 3,300 films 3 0 x 4 0 cm.) shall be
stored in a safe unless a large depot is used. Only types of cupboards
1

Betriebsräume — rooms in which the main business of the institution is carried on.
6

82

LEGISLATIVE

MEASURES

certified by the Federal Chemical and Technical Institute (ChemischTechnische Reichsanstalt) as satisfying the following requirements,
shall be deemed to be X-ray film safes:
The cupboard shall not hold more than 150 kg. net weight of films
in the usual protective wrapping (hanging envelopes, portfolios, etc.)
and shall be so subdivided that no compartment holds more than 40 kg.
The compartments shall be so interlocked that only one can be
opened and pulled out at a time.
The cupboard shall be so constructed that no inside pressure
capable of bursting it can arise (Appendix 2).
In the event of a fire outside, the films in the closed cupboard
should not undergo flameless decomposition or be ignited in less than
half an hour (outside fire test).
If the films in an open compartment burn away, or if the films in a
closed compartment flamelessly decompose, the films in the remaining
compartments should neither ignite nor smoulder (inside fire and
smouldering tests).
In conformity with the indications on the test certificate of the
Federal Chemical and Technical Institute, every safe must bear, in
addition to a specification of the type (in words) and as an indication
of its having been approved as a safe, the letters "CTR " (ChemischTechnische Reichsansialt) together with a number (registered number)
and an indication of the authorised .quantity of film storable (e.g.
Filmschutz (film protector) CTR, 2037, 120 kg.).
The room in which the safe stands shall, independently of the type
of safe used, have fire-resisting walls and at least a fire-obstructing
(feuerhemmend) ceiling as well as at least fire-obstructing smoke-tight
and self-closing doors (of hard wood, or soft wood covered on all sides
with sheet metal). Apart from the vestibules, the store-room shall not
communicate with any other room. It shall have a window giving on
to the open, at least 0.5 sq. metres in area and made of thin window
glass.
In addition there shall be a ventilating device with an outlet of at
least 0.25 sq. metres clear, opening automatically at an internal pressure
not exceeding 6 kg. per sq. metre. Any ventilation shafts that may
exist shall not communicate with any other room. Any heating pipes
and radiators shall be provided with protective coverings of such a
form that films cannot be put or laid on them. Stoves with fire or
ash doors in the room shall be prohibited. Iron stoves shall be prohibited. Apart from film's, no inflammable materials shall be stored
in the room.
Several sub-archives, even in the same building, shall be allowed,
but shall not communicate directly one with another.
II. — Storage of X-ray films to an amount exceeding 150 kg. net weight
per room (large depots, archives).
(a) In buildings which are constantly occupied by persons, the
installation of large depots shall be allowed only on the top story.
The walls of the store-room shall be fire-iS sisting, and at least
one brick thick, or equivalently protected against internal pressure
and outside heating. The exit doors shall be fire-resisting and selfclosing. The separation from the neighbouring top-story rooms shall
be such that propagation of a fire inwards from, the outside, or vice
versa, is as far as possible excluded. The floor shall not be combustible.

GERMANY

83

The room shall be so situated that the gases given off by the films
in the event of a fire cannot reach staircases and vestibules used by
persons not employed in the film depot. Otherwise there shall be two
fire-resisting, self-closing and smoke-tight doors between the storeroom and the stairs. If the top story is also constantly occupied by
persons, it shall have a way of escape not threatened by the depot.
Staircases providing means of access to large depots shall have at the
top a ventilation door at least 0.5 sq. metres in area and actuated from
the ground floor.
(b) Storage buildings exclusively used for housing films shall be so
situated that in the event of a fire in the depot, neighbouring buildings
constantly occupied by persons are not affected; and shall have fireresisting outside walls. Doors not leading into the open shall be fireresisting.
Storage buildings with iron outside walls shall be allowed if they are
at least 12 metres distant from non-fire-resisting structural parts. The
floors of such storage buildings shall not be combustible.
If a storage building of the type described above is installed on a
roof, the fire-resisting floor shall project one metre beyond the outside
walls of the storage building on all sides.
No inflammable material shall be stored within 5 metres of the
storage building.
(c) Every room of a large depot shall be provided with a window
opening giving on to the open and having an area of at least 5 per cent.
of the floor space of the room, but in any case not less than 0.5 sq. metres.
The window shall be made of thin window glass and shall be protected
against the glare of the sun (panes of frosted glass or a coating of paint).
The room shall be lighted only by daylight or electric filament lamps
with protective globes.
"With respect to the electrical equipment, the room shall be deemed
to present explosion risks (cf. the regulations of the Association of
German Electrical Engineers for rooms presenting explosion risks,
V.E.S.l ] ) (Appendix 3).
For heating, only low-pressure steam or hot-water systems shall
be employed. The radiators and the heating pipes shall be provided,
at a distance of at least 20 cm. and at least 50 cm. respectively, with
perforated protective covering so shaped that no object can be put
or laid on them. Heating pipes of which the temperature may rise to
over 100° C. shall also be covered with a non-conductor of heat.
Chimneys shall have no openings in the room. If chimneys run
along the walls of the depot, the heating of the chimney walls shall
entail no dangers for the film stocks stored.
The simultaneous storage of other celluloid films, including cinematograph films, for example, shall be allowed in the depot.
The use of the depot for other purposes than the storage of films
shall not be allowed.
No one room shall contain more than 4,000 kg. net weight of films
(i.e. about 246,000 films 18x24 cm. or 88,000 films 3 0 x 4 0 cm.).
When larger quantities are stored, more than one room shall be
provided equipped in conformity with the above provisions. These
1
Vorschriften des Verbandes Deutscher Elektrotechniker für explosionsgefährdete Räume, V.E.S.l.

84

LEGISLATIVE MEASURES

rooms shall not communicate directly one with another, but shall have
separate entrance doors complying with the above provisions.
Buildings containing large film depots shall be protected against
lightning.
PART

III:

TRANSITIONAL,

PENAL

5. Transitional

AND FINAL

PROVISIONS

Provisions

(1) Deviations from the structural provisions of section 4, I i> and
II, which having regard to local conditions appear unobjectionable,
may be allowed by the competent authoiities.
(2) X-ray film cupboards in existence at the time that these
regulations came into force, and not complying with the provisions of
section 4, I b, may continue to be used provided thac in the opinion
of the competent authorities they constitute no danger to human life
or health.
6. Penal Provisions

7. Final Provisions
The present regulations shall come into force on 1 January 1932.
New small and medium-sized depots shall be notified to the subordinate
administrative authorities within four weeks of their installation, and
already existing depots not later than . . .
Large depots shall require the approval of the intermediate administrative authorities.
APPENDIX 1
Leaflet concerning the Handling and Storage of X-Ray Celluloid
Films
Smoking is prohibited in all rooms containing developed films.
Use no bare flames and store no inflammable substances in depots
containing more than 5 kg. of developed films.
Never deposit films near radiators or fireplaces.
Do not leave films lying about loose; after use put them in the
storage containers; always shut the containers.
Test automatic ventilators to see if they work easily.
If a large depot is installed in a special building do not store inflammable substances within a radius of 5 metres.
Keep the films out of the sun's rays.
Do not throw away or burn unutilisable films but treat them as good
films until they are disposed of.
If a fire breaks out extinguish it at once; if you cannot do so shut
film containers whose contents have not caught alight; open or break
the windows ; leave the room ; shut the doors ; call the fire brigade.
Maximum quantities of films storable per room:
Main rooms:
(1) unexposed films: 10 kg. net (in the original packing);
(2) developed films: 5 kg. net (in the special containers for the
purpose).
Sub-archives : 150 kg. net (in safe).

85

GERMANY

Large depots (archives): 4,000 kg. net.
Check the weight of the quantity stored from the following table.
TABLE OF WEIGHTS FOR X-RAY CELLULOID FILMS
( 1 sq. metre X-ray film — 37S grm.)

Net weights oí various quantities of iilms
Size

Net weight
per dozen

Net weight

Size

cm.

grm.

kg-

cm.

Number
Actual

9x12

48.6

13x18

105.3

18x24

194.4

24x30

324

30x40

540

40x40

720

40x50

900

Dozens

5
5
5
5
5
5
5

9x12
13x18
18x24
24x30
30x40
40x40
40x50

1,240
575
308
185
110
83
66

103
48
26
16
9
7
6

10
10
10
10
10
10
10

9x12
13x18
18x24
24x30
30x40
40x40
40x50

2,480
1,150
616
370
220
166
132

206
96
52
32
18
14
12

150
150
150
150
150
150
150

9x12
13 x 18
18x24
24x30
30x40
40x40
40x50

37,200
17,250
9,240
5,550
3,300
2,500
2,000

3,090
1,430
765
465
278
210
167

4,000
4,000
4,000
4,000
4,000
4,000
4,000

9x12
13x18
18x24
24x30
30x40
40x40
40x50

990,000
460,000
246,000
148,000
88,000
66,000
53,000

82,000
38,000
20,400
12,400
7,400
5,600
4,400

APPENDIX 2
Testing of Safes as regards Protection afforded to the Films in them
against Fire and Heat
The testing of safes as regards the protection afforded to the films
in them against fire and heat shall be effected by an outside fire test,
an inside fire test and a smouldering test.
The outside fire test shall simulate a violent wood fire. This shall
be effected, in a test carried out in the open, by allowing flames from
a pile of wood to close over the safe.
The compartments shall be filled as far as possible to their full
capacity with films and in the manner prescribed for storage (hanging
envelopes, portfolios, film envelopes, etc.). It fewer films are used, they

86

LEGISLATIVE MEASURES

shall be so arranged as to be exposed to the greatest heat. In front of
every compartment, and in the foremost wrapping, a maximum thermometer shall be inserted to give an indication of the temperature inside
the safe.
Around the safe shall be heaped up a pile of split pine logs 33 cm.
long. In front and at the sides, the height of the pile shall be rather
less than half that of the safe (0.45 h.), and at the back about onequarter the height (0.25 h.). The -wood shall be stacked in regular
crosswise formation so that the air can easily blow through; and an
ample supply of wood wool shall be laid in the interstices so that the
fire may burn up quickly. More wood shall be put on if the pile sinks
so far that the flames no longer play round the safe. In windy weather
an endeavour shall be made, by piling wood in front, to keep the safe
continuously and entirely in the flames.
The half-hour's duration prescribed for the outside fire test shall
be reckoned from about five minutes after the lighting of the pile of
wood.
The inside Are and smouldering tests should establish whether, in
the event of the burning away or flameless decomposition of the films
in one compartment, the films in the other compartments are adequately
protected against the propagation of the fire or flameless decomposition
resulting from conduction of the heat generated.
Whenever possible the largest compartment shall be filled to at
least 80 per cent., and the other compartments to at least 20 per cent.
of their full capacity with films in the above-mentioned storage conditions (portfolios, envelopes, etc.). In these compartments the films
shall be packed tightly against the front wall so that they are exposed
to the greatest possible heat; and a maximum thermometer shall be
placed underneath at the front of the compartment and in the first
film container.
In the first-mentioned compartment the films in about the tenth
portfolio from the front shall be ignited. For the inside fire test the
compartment shall be left open at least 10 cm., and after the films have
burnt away vigorously, which takes about ten minutes, the flames
shall be extinguished. For the smouldering test the compartment shall
be closed quickly, upon which flameless decomposition (smouldering)
of the films will begin.
Before every test the safe shall be cooled to at least blood temperature.

APPENDIX 3
Extract from the Regulations and Practical Rules for the Erection of
Power-Current Plant with Working Pressures under 1,000 Volts,
compiled by the Association of German Eleetrical Engineers.
2.
(c) Workshops and store-rooms presenting explosion risks shall be
held to be rooms in which explosive materials are manufactured, processed or stored, or in which experience has shown that highly explosive
gases, vapours, dust, or mixtures of the same with air accumulate.
35.
Workshops and store-rooms presenting explosion risks.
(a) Electrical machines, transformers and resistances, etc., switches,
fuses, plugs and similar apparatus in which when working the current
is interrupted, or heating occurs, shall only be used if constructed or
installed so as to be explosion-proof in the special conditions of the
environment.

GERMANY

87

(b) Fixed wiring shall only be used in closed tubes or in the form
of lead cable, or in forms resembling cable.
(1) Special attention shall be paid to protection against mechanical damage.
(c) For lighting, only filament lamps shall be allowed; they shall
be provided with strong outer covers and wire guards.
Regulations concerning the Structural Arrangement and Installation
of Cinematograph Theatres, and the Safety of Cinematograph
Performances, dated 19 January 1926 (II, 9, No. 709), as amended
in accordance with the Federal Decrees of 1 December 1926 (II, 11,
No. 1054) and 26 May 1930 (II, C, No. 1250).
«

„

I. — GENERAL PROVISIONS

1. Scope
(1) The present regulations shall apply to:
(a) public cinematograph performances;
(b) private cinematograph performances in premises that have
been provided by the owner by way of business or against
payment;
(c) cinematograph performances arranged by associations in
the conditions mentioned in (a) and (b);
(d) school cinematograph performances.
(2) By "occupier " of a cinematograph theatre shall be meant the
manager of the performance. If the said manager is not fully capable
of conducting business, or is not an adult, or not domiciled in the
district, or if there are several managers, or one manager owns several
cinematograph theatres, then responsible representatives shall be
notified by name and in writing to the competent police authorities.
The representative shall be deemed to be the occupier by the police
authorities.
(3) During the performance the occupier shall be continuously
present in person or shall be represented by a suitable person.
2. Notification, Licensing and Supervision
(1) Cinematograph performances shall not be begun before the
building inspection authorities have issued a certificate to the effect
that all rooms and installations in the theatre satisfy the requirements
of the present regulations; and that the projector is constructed and
installed in the regulation manner, and provision has been made for
its proper operation.
(2) Admission to every room in the cinematograph theatre shall
be allowed at all times to police and fire brigade officials responsible
for inspection and supervision, to the competent factory inspectors, and
to the technical inspection officials of the Mutual Accident Insurance
Association of the Fine Mechanical and Electrical Engineering Industry
(Berufsgenossenschaft der Feinmechanik und Elektrotechnik).
IL —- STRUCTURAL ARRANGEMENTS XND INSTALLATION
OF CINEMATOGRAPH THEATRES
A
3. General
- — Situation
(1) Cinematograph theatres shall not be installed in buildings in
which there are factories or workshops for inflammable materials, or
store-rooms for highly inflammable articles.

88

LEGISLATIVE

MEASURES

(2) On sites on which there are buildings and undertakings or
store-rooms of the kind specified above, cinematograph theatres may
only be built if the vestibules and passage-ways leading to the theatre
are completely separated from those leading to the said undertakings
or store-rooms, and if the building inspection authorities consider the
other precautions taken sufficient.
4. Theatres for more than 2,000 Persons
As a rule, cinematograph theatres for more than 2,000 spectators
shall have main exits on different public roads. To this, an exception
shall only be allowed if between the main exits and the road there
are courtyards, gardens, or open spaces of such dimensions as to be
capable of accommodating all the people in the theatre, at least 1 square
metre being reckoned for every three persons in excess of 2,000.
5. Theatres holding up to 2,000 Persons
(1) Cinematograph theatres holding up to 2,000 persons shall, as
a general rule, be so situated that the main entrances and exits lie
on a public thoroughfare, or at least on a public road not less than
10 metres wide and provided with a place for motor-cars to turn in.
If the road is narrower, the front of the cinematograph theatre shall
be set back so far from the building line that at least the prescribed
distance from the opposite buildings is preserved. The place so
obtained shall be clear of buildings or obstructions.
(2) A position on a public road may not be required if the main
entrances and exits are on two opposite lengthwise sides of the theatre
and lead on to courtyards.
(3) For theatres accommodating from 200 to 1,200 persons, all
courtyards serving to evacuate the theatre shall be at least 6 metres
wide, and for theatres accommodating from 1,200 to 2,000 persons
at least 9 metres wide. Further, they shall be so spacious as to be
capable of accommodating the part of the audience utilising them
(reckoning four persons to 1 sq. metre); and communicate with the
road by approaches or passage-ways, and with one another by a passageway or way round. The approaches, passage-ways or wavs round
shall be at least 4 metres wide, and have a roadway at least 2.30 metres
wide and raised pavements. The pavement shall be 1 metre wide
for every 200 spectators having to use the approach, etc.
(4) Vestibules inside the theatre that lead directly to the road and
serve to evacuate the theatre may be reckoned in the width of the
pavement if they are at least 2 metres wide.
6. Theatres holding up to 200 Persons
For cinematograph theatres holding less than 200 persons and
having a floor not more than 4 metres above the street level, it shall
suffice if the exits lead on to a courtyard of adequate dimensions.
The courtyard shall, by a passage-way or approach, connect with a
street that is at least 3.30 metres wide and has raised pavements
with an over-all width of 1 metre.
7. Special Requirements
The approaches and passage-ways, and the vestibules inside the
theatre, serving for its evacuation shall have no openings in the ceiling.
In the walls of the approaches and passage-ways openings may be
allowed as an exception if the over-all width of the said approaches

GERMANY

89

and passage-ways exceeds the minimum prescribed for the corresponding number of spectators.
B. — Walls and Ceilings
8. Outside Walls
The outside walls of cinematograph theatres, the walls of all
necessary stairs, vestibules, approaches, and passage-ways, and the
walls of smoke and air vents and of skylights between ceiling and
roof shall be made fire-resisting. The walls of smoke and air vents
shall be carried 50 cm. above the roof. Door and window openings
in outside walls shall be at least 6 metres distant from the boundaries
of neighbouring property, other buildings on the same site, and opposite
parts of the same building.
As an exception to the provisions of the above paragraph, the
walls of one-story cinematograph theatres may be made fire-obstructing
(feuerhemmend).
9. Ceilings, Skylights
(1) The ceilings of all rooms that lie under rooms intended for
constant occupation by persons, and the ceilings of the vestibules,
approaches and passage-ways shall be made fire-resisting. The
ceilings of the other rooms, including the staircases, shall be fireobstructing. As an exception to this, in cinematograph theatres
holding less than 200 spectators and with a floor not more than 4 metres
above the street level fire-obstructing ceilings, and in enclosed cinematograph theatres the ceiling of which is at the same time the roof,
unplastered planed wood ceilings shall be allowed. Basements and
galleries shall not be counted as stories for the purpose of this provision.
(2) Skylights that are not covered with wired glass shall be provided underneath with wire netting.
(3) The roofs shall be covered so as to be fire-obstructing.
C. — Vestibules, Stairs, Courtyards, Passage-Ways and Exits
10. General
Vestibules, stairs, courtyards, passage-ways and exits shall be
given such dimensions, and while the theatre is open be so lighted,
that the theatre can be evacuated easily, in good order and safely
by the shortest way. Fittings in the vestibules and on the stairs
obstructing the movements of people shall be prohibited. The nearest
way to the exits shall be indicated in the auditorium, corridors and
stairs by red, well-illuminated arrows. The exits shall be indicated
as such in distinct and easily legible characters.
11. Vestibules
(1) The vestibules serving to evacuate the theatre shall be 1 metre
wide for every 125 persons up to 600, and for every 165 thereafter,
but in no case less than 2 metres. Wall tables, wall seats, wash boards,
etc., shall not project more than 15 cm. The regulation width of
the vestibules shall not be diminished by door leaves or cloakrooms.
(2) Steps along vestibules shall be prohibited. Stairs of at least
five steps may be allowed by way of exception, provided that each
step is lighted, the whole is lighted from above, and at least one of
these systems of lighting is connected with the emergency lighting.

90

LEGISLATIVE MEASURES

(3) Ramps shall not have a slope exceeding 1: 10, and before and
after stairs the slope shall only begin at a distance equal to the utilisable
width of the stairs.
12. Stairs
(1) All stairs required to evacuate the theatre (section 10) shall
be of fire-resisting construction, and have on both sides handrails or
runners made of incombustible material or hard wood, and without
free ends. For cinematograph theatres that do not lie higher than
the first story, and over which there are no rooms intended for constant
occupation by persons, fire-obstructing stairs shall suffice.
(2) Essential stairs shall not overhang and not communicate with
the basement. They shall lie in special staircases that receive light
and air, through windows in the outside walls, direct from the street
or from a regulation courtyard. Stairs serving to evacuate galleries
shall not lead directly into the auditorium, but shall have special
vestibules or entrance lobbies, the exits of which are so arranged that
if the parquet and the galleries are evacuated simultaneously there
are not two opposing streams of people.
(3) The total width of the stairs shall be such that for cinematograph theatres with a gallery the stairs are 1 metre wide for every
10O spectators; for theatres without a gallery and holding up to 600
spectators, 1 metre wide for every 125 persons; and for larger theatres
of the latter type, 1 metre wide for every 165 persons over 600. The
distance between the handrails on stairs shall be not less than 1.25
metres and not more than 2.5 metres. As an exception to this,
stairs of galleries holding not more than 125 persons may be 1 metre
wide. Cinematograph theatres and parts thereof not standing on the
ground level shall have at least two sets of stairs.
(4) Stairs standing clear shall have a landing at least 80 cm. wide
before the exit doors, and if they are essential stairs, shall be allowed
only to a height of 2 metres above the ground. Spiral stairs shall
be allowed only exceptionally and for subsidiary purposes.
(5) The steps of stairs shall have a tread at least 30 cm. wide and
shall not be more than 16 cm. high. For stairs with turnings, the
width of the tread on the narrower side shall not be less than 23 cm.
Doors leading to stairs shall be at a distance from them equal to the
width of the door leaf, and in any case at least 80 cm.
(6) Compartments under stairs shall be prohibited.
13. Exits
(1) The over-all width of exits leading into the open shall be at
least 2 metres and shall be reckoned as for vestibules. Doors up to
1.50 metres wide shall be allowed if the main leaf is one metre wide,
and the fixed leaf can be easily opened from the inside by a single
downward movement from a height of about 1.20 metres above the
floor.
(2) If in the same building there is more than one cinematograph
theatre, or, in addition to a cinematograph theatre, other theatres,
assembly rooms or other premises having no business connections
with the cinematograph theatre, the spectators shall not have to use
common vestibules, stairs or exits. In new buildings separate stairs
and exits shall be provided for every theatre, assembly room or such
other premises.

GERMANY

91

D. — Doors and Windows
14. Doors
(1) Doors shall open outwards and shall have no threshold. Projecting leaves or leaves swinging right back may project not more
than 15 cm. into the vestibule, but shall not diminish the prescribed
width of the vestibule.
(2) The locks of the auditorium doors shall be easily openable
from the inside by a single downward movement from a height of
about 1.20 metres above the floor. Open door leaves shall be held
against the walls by self-acting springs. Flush bolts or sliding bolts
shall be prohibited on doors.
15. Windows
(1) The windows of the auditorium shall have at least one movable
casement not less than 35 cm. wide and 1.25 metres high, easily
openable from inside by a single movement. Gratings shall only be
so affixed to windows that they can be opened simultaneously with
the windows and do not impede opening.
(2) Windows giving on to light wells shall have an iron frame and
panes of wired glass or electrical glass so fastened in that they do not
fall out under the influence of heat.
(3) In pay-boxes, fixed window gratings may be allowed according
to local conditions.
E. — Auditorium
16. General
(1) In cinematograph theatres holding up to 600 spectators the
parquet floors shall not be more than 12 metres and in larger theatres
not more than 8 metres above the ground. The last row of seats in
the auditorium shall be at least 2.30 metres below the ceiling.
(2) In cinematograph theatres only one gallery shall be allowed,
unless an ordinary theatre has been converted into a cinematograph
theatre and the structural regulations for ordinary theatres are observed. The clear height under the gallery shall also be at least
2.30 metres. The gallery shall not have more than ten rows of seats
one behind another. If more than ten rows are installed, there shall
be separate gangways with separate stairs for every ten rows.
(3) The walls shall be covered only with slow-burning or pasted-on
material. Ceiling coverings of stuff shall not be allowed.
17. Exits
(1) The exits shall be in such numbers and so distributed that
orderly and easy evacuation is ensured. For calculating the over-all
width of the corridors and exits, the provisions of section 11 shall
apply. There shall be at least two exits, which in the case of theatres
holding more than 600 spectators shall be on two opposite lengthwise
sides.
(2) In theatres on the ground level, and in favourable general
conditions, exits leading into the open shall also be allowed on the
two crosswise sides, if the auditorium is evacuated from the lengthwise
sides through vestibules. By lengthwise sides shall be understood
sides perpendicular to the rows of seats in the theatre.
(2) The aisles in the parquet shall have no steps, and shall have
a slope not exceeding 1: 10. The stair steps in the gallery shall have

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LEGISLATIVE MEASURES

a tread at least 30 cm. wide and shall not be higher than 10 cm.
Every step shall have its own lighting connected to a source of current
independent of the main lighting.
18. Fixed Seats
If permanent seating is installed in the auditorium the seats shall
be fastened so as to be immovable. The width of each seat shall be
at least 50 cm. The depth of each row shall be at least 80 cm. with
tip-up seats, otherwise one metre. Apart from these minimum depths
of the individual rows, there shall be a free passage-way of at least
0.45 metres between the rows. In the parquet there shall not be more
than fourteen seats in a continuous row leading off the side aisles and
entrance lobbies ; in the gallery not more than twelve seats ; and leading
off from the middle aisles throughout the theatre not more than half
the corresponding number. The foremost seats shall be at least
3 metres from the screen.
19. Movable Seats
If the auditorium is only temporarily provided with tables, chairs
and benches, to allow the circulation of people inside the room the
aisles shall be arranged in conformity, mutatis mutandis, with the
revisions of section 18, and securely separated off. If chairs or
enches are arranged in rows, an interval of 1 metre shall be kept
between the rows. The chairs or benches in each row shall be so
fastened together that they cannot be displaced while in use.

E

20. Theatres with Standing Room
Standing room in cinematograph theatres shall only be allowed in
theatres holding less than 200 persons. If such accommodation is
allowed, at least 1 square metre floor space shall be reckoned for every
two persons standing.
21. Posting up of Seating Arrangements
For every occasion on which it is proposed to use the theatre, a
special plan shall be drawn up showing the position and width of the
aisles; exit doors; the arrangement, number, and size of the seats;
the aisles, stairs, exits and emergency lighting. The plan shall be
submitted to the building inspection authorities, and when approved,
shall be affixed at a conspicuous place in the theatre readily accessible
to the spectators. The arrangements shown in the plan shall not be
altered without the approval of the building inspection authorities.
F. — Cloakrooms and Trading Premises
22. Cloakrooms
(1) Cloakrooms shall not be placed in the narrow parts of vestibules
and shall be so arranged as not to impede the orderly evacuation of
the theatre. They shall be provided with counters. The counters
shall lie so far back from side approaches to the auditorium and from
exits in the vestibule that the width of the vestibule in front of the
counters exceeds the minimum required for the number of spectators
accommodated by at least one-third. For this purpose, pillars shall
not be reckoned in the width of the vestibule; between the pillars and
the front of the counter there shall be a clear space of at least 1.25
metres.

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(2) If the use of the cloakroom is compulsory the number of
clothes-hooks shall correspond to the number of seats. For every
twenty hooks there shall be at least 1 metre of counter.
23. Trading Premises
The installation of premises for the sale of articles and drinks in
cinematograph theatres shall require the authorisation of the building
inspection authorities ; authorisation shall be refused only on grounds
of safety. For the said installations, the provisions of section 22
shall apply, mutatis mutandis. It shall be prohibited to install trading
premises in staircases.
G. — Lighting
24. General
(1) It shall be possible to switch on the electric lighting, or that
part thereof serving more particularly to light the aisles adequately,
from a place suitably situated and conspicuously indicated. The
plant shall be so designed that, in the event of a fire in the operator's
box, the lighting installation of the auditorium cannot be endangered.
The aisles and the doors of the auditorium shall be particularly well
lighted.
(2) Freely suspended light fittings shall be carefully, and if heavy
or high above the floor, doubly fastened. The leads of electric lamps
shall not be used for suspension purposes. The bottom of the light
fittings shall be at least 2 metres above the floor level. In the
case of arc lamps, bell-shaped and spherical lamps shall be provided
with wire-net guards.
25. Supervision of the Installation
Before being taken into use, and thereafter once a year, the electric
and gas lighting installation shall be inspected by an expert, approved
by the chief of the local Government {Begierungspräsident).
The
results of the inspection shall be communicated to the building inspection authorities.
26. Electric Lighting
(1) Until further notice, electric lighting installations shall comply
with the regulations of the Association of German Electrical Engineers
concerning the installation and operation of electric power-current
plant 1 . A wiring diagram showing the grouping of the lights in the
auditorium shall be posted up conspicuously in the immediate vicinity
of the main switchboard.
(2) Transformer and oil-switch equipment shall only be placed in
rooms so situated that in the event of ignition or explosion of such
equipment there is no likelihood of any danger for the spectators.
27. Gas Lighting
(1) With gas lighting installations, the distance between the gas
flames and inflammable materials shall be at least 1 metre vertically,
and at least 60 cm. horizontally. If these distances cannot be maintained, there shall be fitted sheet-metal guards of adequate size not
1
Vorschriften des Verbandes deutscher Elektrotechniker für die
Einrichtung und den Betrieb elektrischer Starkstromanlagen.

94

LEGISLATIVE MEASURES

resting on inflammable materials. No lead piping or loose flexible
tubing of any kind shall be used; only fixed piping shall be allowed.
The stop-cocks on the piping shall be so placed that they cannot be
used by unauthorised persons, and burner taps shall not be provided
•with fixed keys. Movable gas arms shall only be allowed when their
movements are so limited that they always keep the distance prescribed above from inflammable materials.
(2) Gas meters shall only be installed in rooms that are enclosed
in fire-resisting walls, have a fire-obstructing ceiling without openings,
and can be lighted and ventilated from the outside.
28. Mineral Oils
Mineral oils shall be employed for lighting only as an exception
and subject to the approval of the building inspection authorities.
H. — Emergency Lighting
29. General
(1) Apart from the main lighting system, there shall be provided
emergency lighting completely independent of it. The emergency
lighting shall be such that the spectators can find their way about
even if the main lighting completely fails. The auditorium doors,
the vestibules, stairs, courtyards, passage-ways and exits shall be
particularly well lighted, and doors leading directly into the open
shall be indicated by red lamps. During the performance the
emergency lamps in the auditorium shall be dimmed only so far as
to leave the doors fully lighted.
(2) Care shall be taken that the emergency lights can burn for
the whole duration of the performance or can be turned on by relay
switching. The "duration of the performance " shall mean the time
from the admission of the spectators until the last spectator has left.
(3) If the installation offers the necessary guarantees of safety,
as emergency lighting may be authorised emergency lighting supplied
from a special source of current and provided with relay switching.
(4) It shall be always possible to test the source of current for
emergency lamps as to its output capacity.
30. Theatres Holding more than 600 Persons
In cinematograph theatres holding more than 600 spectators, only
electric light shall be used for emergency lighting. The emergency
lighting shall be so installed that either each emergency lamp shall
have its own source of current directly connected to it, or all the
emergency lamps are supplied from a central source of current independent of the main wiring. The lamps shall be connected to their
source of current by means of unbranched wiring enclosed in armoured
or plain unlined conduits.
31. Theatres Holding up to 600 Persons
(1) For emergency lighting in cinematograph theatres holding up
to 600 persons use may be made of:
(a) electric lighting of the type specified in section 30;
(b) electric lighting supplied from the general distribution system,
if electric light is not used for the main lighting;
(c) gas lighting, if gas is not used for the main lighting;
(d) colza oil or candle lamps.

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(2) Lamps burning mineral oil or spirit, and carbide lamps shall
not be used for emergency lighting.
32. Theatres Holding up to 200 Persons
For cinematograph theatres holding up to 200 persons, lying at
the ground level and having good evacuation arrangements, the
building inspection authorities may, in the case of electric main lighting,
authorise the emergency lighting to be supplied from the same distribution system if the emergency lighting leads are branched off before
the main fuses of the main lighting system, unbranched supply and
return wires have been installed, and the wiring of the emergency
lighting is specially protected.
J. — Heating
33. Central Heating
(1) If the cinematograph theatre is heated by central heating the
rooms in which the furnaces are installed, and the rooms for storing
fuel, shall be enclosed in fire-resisting walls, and have fire-obstructing
ceilings without openings. These rooms shall be separated from
adjoining rooms and vestibules by smoke-tight, fire-obstructing and
self-closing doors.
(2) Bare steam and water-heating pipes shall be covered by
materials affording protection against heat, or shall be protected
against contact by removable wire netting, metal sheets, etc.
(3) Conduits for carrying hot air shall be fire-resisting and so laid
that they can be easily dusted. Their outlet openings shall be at least
25 cm. from highly inflammable substances.
(4) Radiators in cloakrooms shall be provided with incombustible
protective casing.
34. Stove Heating
(1) Stoves shall be surrounded by immovable and incombustible
protective casing. The stove chimneys shall be made smoke-tight
and shall be carried directly and in a smoke-tight manner into the wall.
(2) The use of gas-stoves shall not be allowed.
K. — Ventilation
35.
(1) The auditorium shall have at least two doors or windows
leading directly into the open, and so placed that adequate ventilation
is possible. If sufficient ventilation cannot be obtained in this way,
the building inspection authorities may prescribe the installation of
artificial ventilation.
(2) At the top of every staircase there shall be a ventilator providing sufficient ventilation and actuated from the ground floor.
The adjustment of the ventilator shall be ascertainable on the ground
floor at all times.
L. — Fire Extinguishers
36.
Special local police regulations may be issued concerning the
water supply, fire extinguishers, fire alarms and the presence of a
fireman.

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LEGISLATIVE MEASURES

M. — Administrative

Regulations

37. Prohibition of Smoking
(1) In the rooms, entrance halls, corridors, etc., of a cinematograph
theatre it shall be prohibited to smoke, to bring in lighted cigars,
cigarettes or pipes, or to offer for sale or sell cigars, cigarettes or
tobacco.
(2) The building inspection authorities may grant exceptions.
(3) No exceptions shall be granted in respect of the auditorium,
the means of egress, or rooms impairing the safety of means of egress
in the event of a fire.
(4) The occupier or his representative shall see to the observance
of this prohibition and instruct the employees accordingly.
38. Ensuring of Means of Egress
(1) It shall be prohibited to set tables, benches or chairs in aisles,
and spectators shall not be allowed to stand in the aisles.
(2) For the entire duration of the performance, auditorium doors,
vestibules, exits, stairs, passage-ways and courtyards serving to
evacuate the theatre shall be kept clear for movements of people,
and be lighted in conformity with the regulations.
39. Posting up of Regulations
Notices reproducing the provisions of sections 37 and 38 shall be
posted up in the theatre in sufficient numbers and in legible characters.
III.

—

OPERATOR'S B O X

A. — Construction and Size
40. Walls and Exit
(1) The operator's box shall have fire-resisting walls, at least one
brick thick or of an equivalent construction capable of withstanding
the pressure of the combustion gases; and a fire-resisting ceiling.
Apart from the observation and light ports, it shall have no communication with the auditorium. It shall have an opening for lighting
that leads directly into the open or into an open light well. From
the operator's box there shall be a passage leading directly into the
open and so arranged that in the event ¿f a fire the exits from the
auditorium are not endangered. If the operator's way of escape is
imperilled by the presence of several projectors, another exit shall
be provided.
(2) Door and window openings in the operator's box shall be
provided with a cover affording protection against flames striking
upwards. The said cover shall stand out at least 50 cm. and extend
at least 30 cm. beyond the opening on both sides.
(3) The operator's way of escape shall be kept clear.
41. Dimensions
For a minimum length of 2 metres an operator's box with one
projector shall have at least 6 sq. metres floor space and a clear height
of at least 2.80 metres; for every additional projector installed, the
prescribed minimum floor space of the operator's box shall be increased
by 3 square metres. The height of the ceiling above the operator's

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GERMANY

stand shall be not less than 2 metres. If the operator's box communicates with an adjoining room that satisfies the same requirements,
and in particular has an exit leading into the open, the floor space
may be less than 6 square metres when the building inspection
authorities consider this allowable, but in no case less than 4 square
metres.
42. Observation Ports
The observation ports shall not. measure more than 250 sq. cm.
The light ports shall not be larger than required to allow the passage
of the beam of light. Both sets of openings shall be closed smoketight by means of glass plates at least 5 mm. thick, fixed in an iron
frame or cement plaster. In addition, they shall be equipped with
an iron shutter at least 2 mm. thick, running easily and surely in
guides so that it cannot jam or work out. The shutter shall close
automatically and instantaneously in the event of a fire, and also
be workable by hand.
43. Windows
The windows of the operator's box, and those of the adjoining
rooms communicating with it, shall have an area of at least one-quarter
of a square metre, be filled in with ordinary glass, and be so installed
that in the event of a fire they open easily and automatically as a
result of the pressure generated. It shall be prohibited to fit bolts
on the windows.
44. Doors

The doors leading out of the operator's box, and of the adjoining
rooms communicating with it, shall open outwards, be made firecbstructing, and be so installed that they are easily opened by pushing
from within and pulling from without, and automatically close again.
45. Stairs
(1) If the exit passes over stairs, these shall be at least 65 cm.
wide and provided with hand rails. Their slope shall not exceed
1:1. A part of the stairs not exceeding 1.50 metres in height may
lie in the operator's box.
(2) Ladders shall not constitute the sole means of access to the
operator's box.
B. — Lighting
46. Electrical Equipment
(1) The operator's box shall contain only such electrical equipment
as is required for lighting, heating and ventilating the box, and for
the projector and the film-winding mechanism, together with a switch
for switching on the main lighting in the auditorium. As required
by section 24 (1) of these regulations, the electrical equipment shall
always be so installed that, in the event of a fire in the operator's
box, that part of the lighting which has to be switched on from a
place in the auditorium remains in working order and is not extinguished even if the operator's box is completely destroyed.
(2) It shall also be possible to switch off all the electrical equipment
in the operator's box from a place outside.
(3) The lighting shall only be provided by electric lamps burning
in a vacuum and fitted with wire guards or outer globes.
7

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LEGISLATIVE MEASURES

47. Resistances
The electrical resistances shall be provided with a sloping or convex
cover or shall be installed so high that articles cannot be laid upon
them. Movable resistances shall not be installed either directly
under the projector or near the film-winding mechanism.
48. Emergency Lighting
If the means of access are poor, connection to the emergency
lighting may also be required in respect of the way of escape from
the operator's box.
49. Supervision
The electrical equipment shall comply with the regulations of the
Association of German Electrical Engineers. Before being taken into
use, and there after once a year, the equipment shall be inspected by oan
expert approved by the chief of the local Government (Regierungspräsident). The certificates issued in respect of the inspection shall be
submitted to the building inspection authorities.
C. — Heating and Ventilation
50. Heating
(1) For heating, stoves shall only be allowed when their fire doors
lie outside the operator's box.
(2) The stoves or radiators shall be at least 1 metre from the
projector, and enclosed on all sides by a mesh guard, the top of which
slopes like a roof so that no objects can be laid on it.
(3) The use of -iron stoves or gas-stoves shall in no case be allowed.
51. Ventilation
If the ventilation is poor, it shall be left to the discretion of the
building inspection authorities to prescribe trie installation of mechanical ventilation.
D.—- Protection of Films
52. Stock of Films
In the operator's box not more than the day's requirements of
films shall be stored. The reels of films, apart from one each allowed
in the projector and the winding mechanism, shall be stored in a special
container installed as far as possible from the projector and at least
1 metre above the floor.
53. Film Containers
As a rule, the film container shall be made of hard wood. I t shall be
divided by vertical partitions into compartments holding one film reel
each. Each compartment shall be separately closed by a shutter that
runs vertically in grooves, falls by its own weight, shuts tight, and
cannot be pulled out.
54. Film Reels
(1) Film reels shall be kept enclosed in drums, and so made that in
the event of a fire, the part of the film outside the drum is protected as
well as possible against ignition. In this connection it shall also be

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99

required that films shall enter and leave the drum by means of a slit
sufficiently long, as narrow as possible and edged with metal. The
sides of the drums shall be provided with openings filled in with fine
mesh so as to prevent the penetration of flames.
(2) The drums shall be so constructed that any performance with
the drums open is effectively prevented.
55. Film Adhesives
In the operator's box there shall not be more than 30 grm. of highly
inflammable film adhesives.
56. Film-winding Mechanism.
The film-winding mechanism shall be at least 1.50 metres from the
projector.
E. — Other Equipment
57. Projector Table.
The projector table shall be made of incombustible material, and
have at a suitable place a metal container, with sand at the bottom,
to hold used pieces of carbon.
58. Fire Extinguishers
There shall be water piping in the operator's box. At the side of
the projector there shall be kept in readiness a pail with at least 8-10
litres of water, and an impregnated blanket difficult to ignite (fire
protection blanket), or a wet cloth.
59. Other Appliances
For the rest, in the operator's box there shall be only such equipment and appliances as are absolutely essential for the performance,
and these shall be made of material that is difficult to ignite.
60. Seating Accommodation
A seat, cloakroom and washing facilities shall be provided for the
operator in the operator's box, or if possible in its vicinity. A special
sanitary convenience shall be provided, if possible near the operator's
box, for persons employed in the cinematograph theatre.
F. — Working Regulations for the Operator
61. Authorisation
Any person entrusted with the single-handed operation of a
projector shall possess an operator's certificate issued by the competent
operators' testing authority, or approved by the chief of the local
Government. This certificate shall be shown at all times on request
to the persons mentioned in section 2.
62. Stand
(1) The operator shall not leave his stand by the projector and in
particular shall not attend to the winding mechanism while the projector is working.
(2) If two or more projectors are working simultaneously so that
films can be shown without a break, each projector shall be worked by
a separate operator unless the construction of the projectors is such
that they can be worked safely by one operator.

100

LEGISLATIVE

MEASURES

63. Responsibility
The operator shall see that the provisions of Parts III, D and E,
of the present regulations concerning the storage of films and the
equipment of the operator's box are complied with, and that the exits
from the box and any adjoining rooms are always kept clear.
64. Prohibitions
It shall be prohibited:
(a) to deposit films near the projector lamps;
(b) to bring articles of clothing into the operator's box unless they
are kept in cupboards made of incombustible material;
(c) to smoke or allow smoking in the operator's box and in adjoining
rooms communicating with it, or to enter such rooms with bare
lights, lighted cigars, cigarettes or pipes, or to strike matches;
(d) to enter the operator's box, winding room or film store-room
without authorisation, or to allow such rooms to be so entered.
65. Posting up of Regulations
A clearly printed copy of the foregoing provisions (sections 61-64)
and of the provisions of Parts III, D and E, of the present regulations
shall be posted up at the entrance doors of the operator's box and of
adjoining rooms communicating with it.
IV. — REGULATIONS CONCERNING THE PROJECTOR

66. Lamp Casing
(1) The lamp casing of projectors shall be double walled, be provided with a sloping cover, be lined with asbestos or some other poor
conductor of heat, and be so made that incandescent particles cannot
escape from it. Between the outer and the inner wall there shall be a
space of at least 2.5 cm. The outer wall shall be provided with airholes ensuring adequate cooling.
(2) The length of the lamp casing shall be such that the back wall
is at least 20 cm. from the rearmost position of the source of light. The
back wall shall be lined with an incombustible material.
(3) The floor of the casing shall project beyond the walls, and the
edges shall be turned upwards at least 2 cm. so that incandescent
particles cannot fall out.
(4) Any combustion gases given off by the illuminant shall be led
off directly into the open or into a chimney.
(5) The provisions of paragraphs (2) and (3) shall only apply when
use is made of condenser arc lamps or reflector lamps in which the back
wall of the lamp casing is not formed by the reflector holder.
67. Protection of the Projected Film
(1) The film shall be wound off a regulation spool and shall simultaneously be automatically wound on to a similar spool at a constant
speed. The stretch of film between the spools shall be as short as
possible and while within the effective range of the heat and light rays,
be efficiently protected against ignition. In this connection, particular
attention shall be paid to high temperatures at the light aperture. If
the film tears or runs defectively no part of it shall come into contact
with the lamp casing.

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(2) The aperture of the projector shall have a diaphragm, adjustable by hand, and a safety device closing it automatically as soon as the
film runs so slowly as to be liable to ignition either in or at the aperture.
Further, the aperture shall be so made that propagation of fire along
the rest of the film is as far as possible prevented.
68.

Illuminant
(1) As a general rule, electricity shall be used as the projector
illuminant.
(2) By way of exception to the provisions of paragraph 1, the
building inspection authorities may in special cases authorise the use
of a limelight or other similar illumination subject to compliance with
the following provisions :
(a) Burners in which the gases can mix before they issue from
the nozzle may not be authorised otherwise than by way of
exception, and then only if before the outlet a safety device is
fitted preventing the flame from striking back into the nozzle.
In addition, effective precautions shall be taken to prevent
one gas from streaming back into the piping of the other ;
(b) If flexible burner piping is used, it shall be secured against
slipping off the nozzles. The flame shall not be started with a
bare light. Preferably, cerium iron devices shall be used;
(c) Use shall only be made of gas cylinders whose valves comply
with the specifications of the German Industrial Standards
Committee (Normenausschuss der deutschen Industrie — Dinorm,
Blatt 477). Further, the oxygen piping and connections shall
be specially distinguished by blue paint. Oily or fatty packing
shall not be used on fittings and pressure reduction valves for
oxygen and other oxidising gases. Combustible packing materials shall be avoided ;
(d) Gas cylinders shall be so placed that in the event of a cylinder
exploding, which is particularly liable to occur in case of fire,
all danger to the spectators is precluded. It shall be prohibited
to place cylinders in the auditorium. If placed in the operator's
box, exceptions may be allowed for special systems ;
(e) The stock of gas cylinders shall be kept in the open, or in fireobstructing, closed and well-ventilated rooms. When stored
in the open, gas cylinders shall be protected against the direct
action of the sun's rays, and if stored in a busy place, protection
shall take the form of a wooden box or canvas awning. In any
case, gas cylinders shall be secured against tipping over, and
when being transported care shall be taken that they are not
thrown about or jolted.
V. — EXCEPTIONS AND TRANSITIONAL PROVISIONS

A. — Exceptions for Cinematograph Theatres
69. Authorisation of Vestibules adjoining the Operator's Box
The building inspection authorities may, if the general evacuation
conditions are favourable, allow egress from the operator's box to be
afforded by a vestibule when an exit leading directly into the open
cannot be provided. The exit from the vestibule shall in no case lead

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LEGISLATIVE MEASURES

into the auditorium or any room serving for the evacuation of the
auditorium. Further, the vestibule shall not be used for storing
objects of any kind, films in particular.
70. Authorisation of Additional Exceptions
(Exemptions)
The chief of the local Government may authorise additional
exceptions to (exemptions), or relaxations of, certain provisions of the
present regulations in individual cases, according to local circumstances
and after consultation with the building inspection authorities and the
Factory Inspectorate, more especially when only films of low inflammability are used.
B. —• Travelling and Institutional Cinemas
71. Testing of Projectors
In the case of cinematograph undertakings as defined in section 1,
in any place or any circumstance in which an operator's box complying
with the foregoing provisions is not available for the purposes in
question, and the equipment of such a box would be unreasonably
onerous owing to the merely intermittent need of it, the building
inspection authorities may authorise the exceptions specified in
section 73.
72. Testing Stations for Projectors
The safe equipment of the operator's box and the testing of the
projector shall ,bc matters for the testing stations set up by the
competent Ministers.
73. Exceptions
(1) When untested projectors are used, the operator's box may be
dispensed with, if the projector is installed in the open and the beam
of light is thrown on to a screen in the auditorium through a wall
opening not exceeding 250 sq. cm. in area, and closed with a plate of glass
at least 5 mm. thick securely set in masonry. A projector installed in the
open must be at least 3 metres distant in any direction from doors that
may serve as exits for the public.
(2) If a tested Class B projector is used, the provisions of Parts III, A,
B and D, and section 66 (2) may be declared inoperative provided that
the absence of the operator's box renders them inapplicable.
(3) The relaxations specified in the preceding paragraph may also
be allowed when a tested Class C projector is used. If the number of
spectators authorised does not exceed fifty, the foregoing regulations,
except those in Part I and P a r t III F, shall not apply, provided that
having regard to local circumstances no further precautions are called
for.
(4) The authorisation of relaxations shall depend on the projector's being installed in the most suitable place, e.g. in an adjoining
room or a gallery, as far as possible out of sight, not near the spectators,
and so that the ways out are neither narrowed nor endangered.
Further, the film containers shall be of regulation manufacture and
kept outside the auditorium. They shall never be placed near the ways
out. Films shall not be taken out of the drums or wound in the
auditorium.

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(5) Illuminants other than electricity shall only be authorised quite
exceptionally and when, having regard to the circumstances of the
case, there is no cause whatever for apprehension.
(6) Class B and C projectors shall only be furnished with stopping
devices when this is provided for in the permit issued by the testing
authority.
74. Taking over of Tested Projectors
When projector equipment is taken over, there shall be verified
the permit for the projector class in question and, from specifications,
the presence of all projector parts and the regulation assemblage of the
projector.
C. •— School Cinemas
75. General
(1) For non-public cinematograph performances in schools,
subject to the permission of the school inspection authorities or an
authority designated by them, the installation of the projector in a
special room may be dispensed with by way of exception, provided
that only tested projectors are used.
(2) Before a permit is granted by the school inspection authorities,
or an authority designated by them, there shall be a proper verification (section 74) on taking over, including the premises intended for
the performance.
(3) Cinematograph performances going beyond the school curriculum (parents' evenings, etc.) shall comply with the provisions concerning institutional cinemas.
76. Operators
(1) Authority to operate the projector shall only be granted to
persons in possession of a licence issued by the operators' testing
authority, or a testing authority approved as equivalent by the competent Ministers.
(2) Pupils shall only be allowed to operate the projector singlehanded in performances included in the curriculum, and then only
if they are sixteen years of age and the competent teacher takes the
responsibility.
77. Approval
Approval under section 75 shall only be granted subject to the
following conditions:
(a) The drums in use for the performance, and those for storing
films shall only be filled and emptied outside the auditorium,
and shall be of regulation manufacture. Films not in use shall
be stored in regulation containers outside the auditorium. In
the auditorium there shall be no other film but that on the
projector.
(b) If the projector is installed in the auditorium, there shall be no
spectators within at least 2 metres of it. In no case shall the
projector be installed near ways out.
(f) At the side of the projector there shall be kept in readiness a
pail filled with water and a wet cloth or an impregnated
blanket difficult to ignite (fire protection blanket).

104

LEGISLATIVE

MEASURES

(d) Smoking or moving about with bare flames near the apparatus
shall be prohibited.
(e) The auditorium shall be so provided with exits that the spectators can leave it quickly and in good order. Larger rooms
such as halls, studios and laboratories shall always have two
exits, as far as possible on opposite sides.
(/) Only the ordinary seating accommodation shall be occupied.
Standing in the gangways and at the exits shall in all circumstances be prohibited.
(g) The pupils shall be instructed that in case of fire they must
leave the room quietly and in good order.
D. — Transitional Provisions
78.
(1) For existing cinematograph undertakings, the provisions of
Part II, except those under M, shall apply only in so far as is absolutely
necessary on paramount grounds of public safety. The building
inspection authorities shall determine what alterations shall be undertaken in individual cases, and within what time-limits. The final decision shall lie with the chief of the local Government.
(2) The operators' boxes of existing cinematograph theatres shall
be adapted to comply with the provisions of Part III of the present
regulations within two years, without prejudice to the provisions of
sections 58 and 59 and of Part III F, which shall come into force
immediately.
(3) The provisions of Part IV shall be complied with within six
months.
(4) Cinematograph performances which go beyond the school
curriculum (parents' evenings, etc.) and which for structural reasons
cannot immediately comply with the provisions of section 71 and the
following sections shall be allowed a time-limit, expiring on 1 April
1929, for the adaptation of the equipment. In the case of new school
cinemas that desire to give parents' evenings, a similar policy shall
be followed by granting sufficient structural time-limits.

GREAT BRITAIN
In 1912 a special committee was appointed to consider what
regulations might be necessary for the manufacture, manipulation and storage of celluloid or articles made of celluloid, and to
submit a report.
On the basis of this report the County of London Regulations
of 1915 were issued. These prohibit the storage of celluloid or
celluloid films except with the special authorisation of the
London County Council. They also contain provisions respecting
emergency exits, the structural arrangements and situation of
celluloid works and crude-celluloid factories, and for the installation and equipment of hired premises for cinematograph
films.
In 1921 the Home Secretary, in the exercise of his powers
under section 79 of the Factory Act of 1901, issued regulations
covering all factories and workshops in which celluloid or any
article wholly or partly made of celluloid is manufactured,
manipulated or stored. These regulations are mainly concerned
with the position and structural arrangements of celluloid works,
the restriction of quantities of celluloid in the workshops at any
given time, the collection and removal of scrap, the enclosing
of open lights or fires, prohibition of smoking and provision
of emergency exits for use in case of fire.
In 1915 and 1921 respectively, the Corporations of Glasgow
and Liverpool were empowered to issue regulations similar to
the County of London Regulations mentioned above.
In 1922 the Celluloid and Cinematograph Film Act was
passed. It prohibits the storage of celluloid or celluloid film
except in buildings duly authorised by the competent local
authorities, and also contains provisions applying to store-rooms
and workrooms for films. The Act does not apply to London,
Glasgow or Liverpool, where, as has been seen, local regulations
are in force, or to premises covered by the Factory and "Workshop
Act, except in so far as these premises are parts of buildings that
are not exclusively factories or workshops.
In 1928 the Home Secretary published further regulations
entitled (a) the Manufacture of Cinematograph Film Regulations and (ft) the Cinematograph Film Stripping Regulations.
These revoke those parts of the 1921 regulations that relate to
cinematograph films, for experience had shown that more

106

• LEGISLATIVE

MEASURES

precise and stricter regulations were required. The new regulations apply to all factories and workshops in which (a) cinematograph films are manufactured, repaired, manipulated, used
or stored, and (A) stripping or drying of cinematograph film is
carried on'with the object of removing the emulsion before the
films are worked up in t h e varnish or other industries.
It should be pointed o u t t h a t there are no regulations concerning t h e stocking and storing of finished celluloid articles
other t h a n films in buildings, such as retail premises, t h a t are
not covered b y t h e F a c t o r y and Workshop Act.
Celluloid Manufacture, Storage, e t c , Regulations, 1921
Dated 28 November 1921 l
In pursuance of section 79 of the Factory and Workshop Act,
1901, I hereby make the following Fegulations and direct that they
shall apply (except as otherwise provided) to all factories and workshops or parts thereof in which celluloid or any article wholly or partly
made of celluloid is manufactured, manipulated or stored.
Definitions
"Workroom " means a room in which any process in the manufacture of celluloid or any manufacturing process involving the use
of celluloid is carried on.
"Manufacture " of cinematograph film means the production of
negative and positive pictures on a celluloid film and the operations
incidental thereto, including the cutting and perforating of the film.
"Darkroom " means a workroom from which ordinary light has
to be excluded.
• _
,.
Exceptions
For the purpose of these Regulations, celluloid shall not be deemed
to include any material not containing nitrated-cellulose.
Nothing in these P. egulations shall apply to any factory or workshop or part thereof in which celluloid is only used in solution except
as follows: Regulations 5, 6, 8, 9, 12, 14 and 15 shall apply where
celluloid in solution is applied to fabrics of a readily inflammable
nature.
Where the Chief inspector of Factories is satisfied that by reason
of the small quantity of celluloid in use in a factory or workshop at
any one time or for any other re ason all or any of the provisions in the
Regulations are not necessary for the protection of the persons employed,
he may by certificate in writing (which he may in his discretion revoke)
exempt such factory or workshop from all or any of such provisions
subject, to such conditions as he may prescribe.
Duties
It shall be the duty of the occupier to observe Part I of these
Regulations. It shall be the duty of all persons employed to observe
Part II of these Regulations.
1

Statutory Rules and Orders, 1921, Ño. 1825.

GREAT

BRITAIN

PART

107

I

Duties of Occupiers
1. — (i) Stocks of celluloid shall be kept in a suitable place, outside the workrooms, plainly marked "Celluloid Store ".
Stocks of celluloid exceeding one hundredweight shall only be kept
in a chamber constructed of fire-resisting materials, in which no open
light or fire shall be allowed and which shall not be used for any
purpose other than the storage of celluloid.
Any store not complying with the provisions in the foregoing
paragraph shall have a notice "Not to contain more than one hundredweight of celluloid " plainly marked or affixed on the outside of the
door ; and the occupier shall, if so required by an inspector of factories
for the purpose of determining the amount of celluloid in any such
store, cause the same to be weighed in the presence of the inspector.
(ii) The store shall not be situated so as to endanger the means of
escape from the factory or workshop or from any part thereof in the
event of a fire occurring in the store.
(iii) No unauthorised person shall be allowed to have access to
the store.
2. The amount of celluloid in a workroom at any one time shall
be kept as small as is practicable without unduly interfering with the
work carried on. In the case of cinematograph film the amount in a
workroom at any one time shall not exceed the supply immediately
required for the work in hand.
3.-—(i) Celluloid waste created in the process carried on shall not
be allowed to accumulate on the floor of the workroom, but shall be
collected either automatically as created, or at frequent intervals,
in suitable receptacles.
(ii) When work ceases for the day such waste shall be removed
from the workroom and placed in a substantial receptacle provided
with a cover and plainly marked "Celluloid W a s t e " ; provided that
paragraph (ii) shall not apply to a factory or workshop in which
cutlery is manufactured if the waste is kept in a strong metal receptacle
provided with a tight-fitting cover.
4. — (i) Finished articles made wholly or partly of celluloid shall
be removed from the workroom without undue delay and kept in a
suitable place.
(ii) Cinematograph films except while necessarily exposed for
manufacture shall be kept outside the workrooms in suitable
receptacles provided with covers.
5. — (i) Efficient steps shall be taken to prevent celluloid from coming
into contact with open lights or fires, or except to the extent that may
be necessary for the process of the industry, remaining near thereto.
(ii) No open lights or fires shall be. allowed in a room in which
cinematograph film is manufactured or repaired.
6. No person shall be allowed to smoke in any room in which
celluloid is manufactured, manipulated or stored.
7. When a saw is used for cutting celluloid the cutting edge shall,
wherever practicable, be kept constantly wet.
8. —(i) Sealing wax shall not be used on any parcel or package
containing celluloid, unless the articles are packed in tins and the
sealing is done in a room in which no manufacturing process involving
the use of celluloid is carried on.

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LEGISLATIVE MEASURES

(ii) If any package or case containing celluloid requires to be
soldered, efficient steps shall be taken to prevent the solder from
coming into contact with the celluloid.
9. Adequate means for extinguishing fire, having regard to the
amount of celluloid present in the rom at any one time, shall be kept
constantly provided for each workroom and store-room.
10.—(i) Adequate means of escape in case of fire shall be provided
(a) from each floor of the factory or workshop, and (6) in each workroom from all parts of the room, and such means of escape shall be
kept free from obstruction during working hours.
(ii) The doors of a workroom shall, except in the case of sliding
doors, be constructed so as t o open outwards.
(iii) In each workroom other than a darkroom a notice shall be
affixed, in a position where it can be easily read, specifying the means
of escape provided for the persons employed in the room.
Persons working in a darkroom shall be instructed as to the means
of escape from such room.
11. (i) A competent person shall be appointed in writing to
exercise supervision with regard to the requirements of these Regulations and to enforce the observance of them and of any directions
given by the occupier with a view to carrying out the Regulations.
(ii) A printed copy of these Regulations shall be kept posted up
in legible characters in each workroom other than a darkroom and
outside each darkroom in a position where it can be easily read by all
persons employed in the room.
PART

II

Duties of Persons Employed
12. No person shall smoke in any room in which celluloid is
manufactured, manipulated or stored.
13. No person shall use a saw for cutting celluloid, except in
accordance with Regulation 7.
14. No person shall use sealing wax on any parcel or package
containing celluloid, except in accordance with Regulation 8.
15. Every person shall observe such directions as may be given
to him with a view to carrying out these Regulations.
Celluloid and Cinematograph Film Act, 1922
(In force from 1 October 1922)
1. General Safety Provisions
(1) No premises shall be used for any purpose to which this Act
applies :
(a) unless the occupier has furnished to the local authority in
writing a statement of his name, the address of the premises,
and the nature of the business there carried on;
(ô) unless the premises are provided with such means of escape in
case of fire as the local authority may reasonably require, and
such means of escape are maintained in good condition and
free from obstruction;
(c) if the premises are situated underneath premises used for
residential purposes;

GREAT BRITAIN

109

(d) if the premises are so situated that a fire occurring therein
might interfere with the means of escape from the building of
which they form part or from any adjoining building ;
(e) where the premises form part of a building, unless such part
either:
(i) is separated from any other part of the building by
fire-resisting partitions (including fire-resisting ceilings
and floors) and fire-resisting self-closing doors; or
(ii) is so situated and constructed that a fire occurring
therein is not likely to spread to other parts of the
building, and its use for the purpose to which this
Act applies is sanctioned in writing by the local
authority and any conditions attached to such sanction
are complied with;
(/) unless the regulations set out in the First Schedule to this Act
are duly observed;
(g) unless any regulations are duly observed which may be made
by the Secretary of State with respect to the use upon the
premises of any cinematograph or other similar apparatus.
(2) In the case of premises used for any purpose to which this Act
applies at the date of the commencement of this Act, the provisions of
this section requiring the occupier to furnish a statement to the local
authority shall take effect at the expiration of two months after the
commencement of this Act, and the provisions of this section requiring
means of escape in case of fire to be provided shall not take effect until
the expiration of such period as may be reasonably necessary for
enabling the occupier to comply with any requirements of the local
authority in that respect.
(3) Any person aggrieved by any requirement of a local authority,
or the refusal of the local authority to grant any sanction, or by the
conditions attached to any such sanction, may, within seven days after
being notified of such requirement, refusal or conditions, appeal to a
court of summary jurisdiction, provided that he has given not less than
twenty-four hours' notice in writing of such appeal and of the grounds
thereof to the local authority ; and the court on any such appeal may
make such order as appears to the court to be just, including any order
for the payment of costs.
(4) The Secretary of State may, by order made in accordance with
the provisions contained in the Second Schedule to this Act:
(a) make regulations with respect to the use of any cinematograph
or similar apparatus upon any premises used for any purpose
to which this Act applies; and
(b) modify or add to the regulations set out in the First Schedule
to this Act, and those regulations shall thereupon have effect
as so modified or added to.
An order made under this section may apply either generally, or
to such classes or descriptions of premises as may be mentioned in the
order.
2. Purposes to which the Act Applies
The purposes to which this Act applies are:
(1) the keeping or storing of raw celluloid:
(a) in quantities exceeding at any one time one hundredweight;
or

110

LEGISLATIVE

MEASURES

(b) in smaller quantities unless kept (except when required to
be exposed for the purpose of the work carried on in the
premises) in a properly closed metal box or case; and
(2) the keeping or storing of cinematograph film:
(a) in quantities exceeding at any one time twenty reels, or
eighty pounds in weight; or
(b) in smaller quantities unless each reel is kept (except when
required to be exposed for the purpose of the work carried
on in the premises) in a separate and properly closed metal
box or case:
Provided that:
(i) for the purposes of this Act, cinematograph film shall
be deemed to be kept in any premises where it is
temporarily deposited for the purpose of examination,
cleaning, packing, re-winding or repair, but celluloid
or cinematograph film shall not be deemed to be kept
or stored in any premises where it is temporarily
deposited whilst in the course of delivery, conveyance or
transport; and
(ii) the provisions of this Act shall not, except in the cases
referred to in paragraphs (c), (d) and (e) of subsection (1)
of section 1 thereof, apply to premises to which the
Factory and Workshop Acts, 1901 to 1920, apply;
and
(iii) the provisions of this Act shall not apply to premises
licensed in accordance with the provisions of the
Cinematograph Act, 1909.
3. Penalties for Infringement

of Foregoing

Provisions

(1) In the event of any contravention in or in connection with any
premises of the foregoing provisions of this Act, the occupier shall be
liable on summary conviction to a fine not exceeding fifty pounds and,
in the case of a continuing offence, to a further fine not exceeding ten
pounds for each day on which the offence is continued after conviction
thereof.
(2) In the event of the contravention by any person employed on
any premises of any regulation contained in the First Schedule to this
Act or of any regulation made under this Act, he shall be liable on
summary conviction to a fine not exceeding five pounds.
(3) The provisions of section one hundred and fortyrone of the
Factory and Workshop Act, 1901 (which relates to the power of an
occupier to exempt himself from fine on the conviction of the actual
offender), shall apply to offences under this Act as it applies to offences
under that Act.
4. Execution of Act by Local Authorities
(1) It shall be the duty of local authorities to see that the provisions of this Act are duly complied with.
(2) The expenses incurred by a local authority in the execution of
their powers under this Act shall be defrayed in the same manner as
expenses incurred in the administration of the Public Health Acts,
1875 to 1908.

GREAT

BRITAIN

111

(3) The occupier of premises in respect of which a statement is
required to be furnished to the local authority shall pay to the local
authority when furnishing such statement and on the first day of
January of every year thereafter, so long as the premises are used for
any purpose to which this Act applies, such fees as the Secretary of
State may prescribe.
5. Power of Entry
(1) An officer duly authorised by a local authority may, at all
reasonable times, enter and inspect any premises which are used, or
which such officer has reasonable cause to believe are used, wholly or
in part, for any purpose to which this Act applies.
(2) Every such officer as aforesaid shall be furnished with a certificate of his authorisation by the local authority and when visiting
any such premises as aforesaid shall, if so required, produce the said
certificate to the occupier of the premises.
6. Power to Take Samples
An officer duly authorised by a local authority may, at any time,
take for analysis sufficient samples of any material which he suspects
to be or to contain celluloid.
7. Obstruction of Officers
If any person refuses to permit any officer authorised under this
Act to enter or inspect any premises, or hinders or obstructs any such
officer in the execution of his duty under this Act, or refuses to allow
any officer to take samples in pursuance of the last preceding section
or to give him facilities for the purpose, that person shall be liable on
summary conviction to a fine not exceeding twenty pounds.
8. Power of County Court to Modify Agreements and to Apportion
Expenses
(1) If any occupier of premises is prevented by any agreement from
carrying out any structural alterations which are necessary to enable
him to comply with the provisions of this Act, and is unable to obtain
the consent to those alterations of the person whose consent is necessary under the agreement, he may apply, in accordance with rules
of court, to the county court, and the court, after hearing the parties
and any witnesses whom they may desire to call, may make such an
order setting aside or modifying the terms of the agreement as the
court considers just and equitable in the circumstances of the case.
(2) Where in any premises any structural or other alterations are
required in order to comply with the provisions of this Act and the
occupier alleges that the whole or part of the expense of the alterations
ought to be borne by the owner, the occupier may apply, in accordance
with rules of court, to the county court, and the court, after hearing
the parties and any witness whom they may desire to call, may make
such order concerning the expenses or their apportionment as the
court considers just and equitable in the circumstances of the case,
regard being had to the terms of any contract between the parties,
or in the alternative the court may, at the request of the occupier,
determine the lease.

112

LEGISLATIVE

MEASURES

9. Definitions
For the purposes of this Act:
The expression "celluloid" means and includes the substances
known as celluloid and xylonite and other similar substances, containing nitrated cellulose or other nitrated products, but does not include
any substances which are explosives within the meaning of the Explosives Act, 1875.
The expression "raw celluloid " means:
(a) celluloid which has not been subjected to any process of
manufacture; and
(b) celluloid scrap or waste:
The expression "cinematograph film " means any film containing
celluloid which is intended for use in a cinematograph or any similar
apparatus :
The expression "local authority" means county borough councils,
borough councils, urban district councils and rural district councils.
10. Application to Scotland and Ireland

11. Commencement, etc.
(1) This Act may be cited as the Celluloid and Cinematograph Film
Act, 1922, and shall come into operation on the first day of October,
nineteen hundred and twenty-two.
(2) This Act shall not apply to the administrative county of
London or to the city and royal burgh of Glasgow.
(3) The Secretary of State may by order direct that any provisions
of the Liverpool Corporation Act, 1921, relating to the keeping, storing
or manipulation of celluloid and cinematograph films shall cease to
have effect as from such date as may be fixed by the order, but so long
as those provisions continue to have effect this Act shall not apply
to the city of Liverpool.
First Schedule
PART I:

RAW CELLULOID STORES

The following regulation shall be observed in or in connection with
premises where raw celluloid is kept or stored:
All such celluloid shall be kept or stored in a fire-resisting store-room,
and subject to the regulations applying to such store-rooms.
PART II:

PREMISES WHERE CINEMATOGRAPH FILM IS K E P T
OR STORED

The following regulations shall be observed in or in connection with
premises where cinematograph film is kept stored or manipulated:
1. All stock except when actually being used or manipulated shall
be kept either in a fire-resisting store-room and subject to the regulations applying to such store-rooms, or in fire-resisting receptacles
which shall not be used for any other purpose and shall be plainly
marked "Film ".
2. Every reel of film shall, except when required to be exposed
for the purposes of the work carried on in the premises, be kept in a
separate and properly closed metal box.

GREAT BRITAIN

113

3. Not more t h a n ten reels or 40 pounds of film shall be exposed
at. any one time.
4. The following provisions shall apply t o every room used:
(a) for t h e storing; or
(6) for the examination, cleaning, packing, re-winding or repair
of film:
(i) the room shall be used for no other purpose;
(ii) the room shall be kept properly ventilated;
(iii) the adequate means of extinguishing fire, having regard
to t h e amount of film on t h e premises, shall be kept
constantly provided and readily available;
(iv) the furniture and apparatus shall b e so arranged as t o
afford free egress to persons in the room in t h e event
of fire;
(v) no open light or fire shall be allowed;
(vi) the fittings shall, so far as is practicable, be of noninflammable or fire-resisting material;
(vii) the doors shall be self-closing, and shall, except in t h e
case of sliding doors, be so constructed as to open outwards ;
(viii) no person shall smoke in or take matches into t h e r o o m ;
(ix) there shall be kept posted up in large characters in t h e
room:
(a) a printed copy of P a r t s I I and I I I of this Schedule;
(b) full instructions as to t h e action t o be t a k e n in case
of fire; a n d
(c) full directions as to t h e means of escape from t h e
room in case of fire.
5. All celluloid waste and scrap on the premises shall be collected
at frequent intervals and placed either in a fire-resisting store-room,
or in a strong metal receptacle fitted with a hinged lid and marked
"Celluloid W a s t e " .
PART

III:

FIRE-RESISTING

STORE-ROOMS

The following regulations shall apply to fire-resisting store-rooms:
1. The store-room shall be constructed of fire-resisting material
in such manner as to prevent as far as is reasonably practicable any fire
occurring in the store-room from spreading to other p a r t s of t h e premises
or to other premises, and any fire occurring outside t h e store-room from
reaching t h e contents thereof.
2. The store-room shall be properly ventilated.
3. The fittings of the store-room shall, so far as is practicable, be
of non-inflammable or fire-resisting material.
4. Adequate means of extinguishing fire shall be kept constantly
provided and readily available.
5. No open light and no means of heating shall be allowed in the
store-room.
6. If electric light is used, all conductors and a p p a r a t u s shall be
so constructed, installed, protected, worked and maintained as to
prevent danger. Vacuum-type lamps only shall be used, and shall be
in fixed positions and fitted with substantial outer protecting globes.
7. No person shall smoke in or t a k e matches into t h e store-room.
8. The doors of t h e store-room shall be self-closing and shall be kept
securely locked, except when articles are being placed therein or removed
therefrom.
9. The store-room shall not be used for any purpose other t h a n
the keeping of celluloid or cinematograph film, and shall be clearly
marked "Celluloid " or " F i l m " .
10. Not more t h a n one t o n of celluloid and n o t more t h a n five
hundred and sixty reels or one ton of cinematograph film shall be kept
in one store-room:
8

114

LEGISLATIVE MEASURES

Provided that, where a store-room is divided into separate compartments by separate fire-resisting partitions without any openings therein,
each such compartment may, for the purposes of this provision, be
regarded as a separate store-room.
11. When both celluloid and cinematograph film are stored in one
store-room, the aggregate quantity therein shall, at no time, exceed
one ton.
Order No. 403, dated 8 April 1024, respecting the Use of Cinematograph
or Similar Apparatus in Film Stores
In pursuance of section 1 (4) (a) of the Celluloid and Cinematograph
Film Act, 1922, I hereby make the following Regulations with respect
to the use of any cinematograph or similar apparatus upon any
premises used for any purpose to which the Act applies :
1. (a) The projecting apparatus shall be placed on firm supports
constructed of fire-resisting material.
(b) Every lantern shall be fitted with a metal shutter which can
readily be inserted by hand between the source of light and the filmgate and every projector shall be fitted with a metal shutter so
arranged as automatically t o cut off the film-gate from the source
of light when the projector stops.
(c) The construction of the film-gate shall be substantial and such
as to afford ample heat-radiating surface. The passage for the film
shall be sufficiently narrow to prevent flames travelling upwards or
downwards from the light-opening.
2. (a) Projectors shall be fitted with two metal boxes of substantial
construction to and from which the film shall be made to travel, unless
both the film spools are contained in a metal chamber of substantial
construction below the projector. There shall not be more than 2,000
feet of film in either of the two metal boxes.
(b) The film boxes or chamber shall be made to close in such a
manner, and shall be fitted with film slots so constructed, as to prevent
the passage of flame to the interior of the box or chamber, and they
shall remain so closed during the whole time that projection is taking
place.
3. Take-up spools shall be mechanically driven and films shall be
wound upon spools so that the wound film shall not at any time reach
or project beyond the edges of the flanges of the spool.
4. During the projection all films when not in use shall be kept
in closed metal boxes of substantial construction. When in the room
in or from which the films are projected not more than six spools shall
be kept in one box at the same time.
5. These Regulations shall come into force on the 1st day of May
1924.
The Manufacture of Cinematograph Film Regulations, 1928, dated
8 February 19281
In pursuance of section 79 of the Factory and Workshop Act, 1901,
1 2 hereby make the following Regulations and direct that they shall
apply to all factories and workshops or parts thereof in which cinematograph film (as defined below) is manufactured, repaired, manipulated, used or stored.
*2 Statutory Rules and Orders, 1928, No. 82.
i.e. the Home Secretary.

GREAT BRITAIN

115

These Regulations, which may be cited as the Manufacture of
Cinematograph Film Regulations, 1928, shall come into force on
1 March 1928, from which date so much of the Regulations dated
28 November 19211 for the manufacture, manipulation and storage
of celluloid or any article wholly or partly made of celluloid, as relates
to the manufacture, repair, manipulation, use or storage of such
cinematograph film, shall be revoked.
Definitions
" Cinematograph film " means any film, including uncoated raw
base, containing nitrocellulose or other nitrated product which is
intended for use in a cinematograph or other similar apparatus.
"Manufacture of cinematograph film " includes the production of
negative and positive pictures on the film and also the operations incidental thereto, including the cutting and perforating and the projection
of the pictures upon a screen for the purpose of examination.
"Darkroom " means a room from which ordinary light has to be
excluded.
"Fire-resisting material" means:
(a) properly constructed brickwork not less than 4 % inches in
thickness; or
(b) concrete not less than 3 inches in thickness; or
(c) efficiently jointed breeze slabbing not less than 3 inches in
thickness; or
(d) oak or teak not less than 2 inches in thickness; or
(e) glass not less than one-quarter of an inch in thickness in the
centre of which wire mesh is embedded ; or
(/) other approved material.
"Store-room " means a room or chamber or similar enclosure in
which cinematograph film is kept or stored, other than a room in
which a quantity not exceeding twenty reels or 80 pounds in weight,
whichever is the greater, is kept in accordance with the exception to
No. 2 of these Regulations.
"Approved " means approved in writing by the Chief Inspector of
Factories.
Duties
It shall be the duty of the occupier to observe Part I of these
Regulations. It shall be the duty of all persons employed to observe
Part II of these Regulations.
Exception
Where the Chief Inspector of Factories is satisfied that, by reason
of the small quantity of cinematograph film manufactured, repaired,
manipulated, used or stored in a factory or workshop or for any other
reason, all or any of the provisions in these Regulations are not necessary for the protection of the persons employed, he may by certificate
in writing (which he may in his discretion revoke) exempt such factory
or workshop from all or any of such provisions, subject to such conditions as he may prescribe.
1

Statutory Rules and Orders, 1921, No. 1825, p. 240.

116

LEGISLATIVE MEASURES
PART I: DUTIES OF OCCUPIERS

1. Each reel of cinematograph film shall, except when required to
be exposed for the purposes of the work carried on, be kept in a separate
box, properly closed and constructed of metal or of other approved
material.
2. All cinematograph film not being actually used, or manipulated,
or in the course of manufacture or repair, shall be kept in a room or
chamber or similar enclosure satisfying the requirements of these
Regulations with regard to store-rooms, except that a quantity not
exceeding twenty reels or 80 pounds in weight, whichever is the
greater, may be kept in any room provided it is contained in a properly
closed receptacle constructed of metal or of other approved material.
3. (a) All waste and scrap cinematograph film shall be collected
at frequent intervals during each day and be placed in a strong metal
receptacle fitted with self-closing lid, and clearly marked with the
words "Film waste ".
(b) No material liable to ignite spontaneously nor anything likely
to ignite or decompose cinematograph film shall be placed in the
receptacle.
(c) At the end of each day's work the waste and scrap shall be either
transferred to a store-room or removed from the premises.
4. Cinematograph film shall not be manufactured, repaired, manipulated or used in any room unless:
(a) the top of the room is constructed of fire-resisting material:
provided that this requirement shall not apply to any room
on the top floor of a building or to any room of a single-story
building;
(b) the room is separated from any other room or passage by walls
and floor constructed of fire-resisting material;
(c) all the doors of the room are constructed of fire-resisting material and are self-closing;
(d) the fittings are, as far as practicable, constructed of fireresisting material;
(e) the furniture and apparatus are so arranged as to afford unimpeded egress for every person in the room in the event of
fire; and
(/) the room is adequately equipped with fire-extinguishing appliances.
5. (a) Adequate means of escape in case of fire shall be provided
for every building and for every room in which cinematograph film
is manufactured, repaired, manipulated or used, and the means of
escape shall not be deemed adequate unless:
(i) at least two separate safe exits are provided from every such
room and two safe ways of escape from the building are available for all persons employed in the factory or workshop; and
(ii) all doors and windows provided in connection with the means
of escape are so arranged as to open outward readily.
Provided that the foregoing provisions shall not apply where the
factory or workshop forms part of a building from all parts of which
means of escape can be1 required under the London Building Acts
(Amendment) Act, 1905 , or the London County Council (Celluloid,
etcO JLCLJ915 2 .
1
2

5 Edw. 7, c. ccix.
5-6 Geo. 5, c. cviii.

GREAT BRITAIN

117

(b) Intercommunicating fire alarm signals shall be arranged for
every room.
(c) A notice shall be affixed in every room other than a darkroom
and immediately outside each darkroom and in such other parts of the
building as may be named in writing by the District Inspector of
Factories, clearly specifying the means of escape provided for the
persons employed therein.
6. All hatchways, lifts or similar openings between any rooms, or
between any rooms and other parts of the premises, shall be so fitted,
constructed and arranged that fire or products of combustion or decomposition of cinematograph film will not be likely to pass.
7. (a) Every store-room shall be either:
(i) a single-story building in an approved situation; or
(ii) situated on the roof or top floor of a building; or
iii) situated in some other approved position; or
iv) fitted with an efficient automatic water-sprinkling system.
(b) Every store-room constructed or adapted for use as a storeroom on or after 1 March 1928 shall comply with part (i), (ii) or (iii) of
paragraph (a) of this Regulation and shall, in addition, comply with
part (iv).
8. (a) In every store-room situated in accordance with Regulation 7
(a) (i) or 7 (a) (ii) and in any other store-room if so required by notice
in writing from the Chief Inspector of Factories, there shall be a part
of a wall or a part of the roof constructed of ordinary sheet glass
lightly fixed in position, so as to provide a gas relief space in the event
of an explosion or fire occurring within the store-room. The area of
the gas relief space shall not be less than 70 sq. inches and not more
than 90 sq. inches for every 500 pounds of cinematograph film that
may be stored in the store-room.
(£>) The gas relief space shall be protected against external
breakage by a strong wire mesh guard fitted on the outside of the
glass.
(c) The position of the gas relief space shall be such that an outburst of flame through the space would not be likely to endanger the
safety of the building or other premises.
9. (a) Every store-room shall be:
(i) constructed entirely of fire-resisting material except as regards
the gas relief space;
(ii) fitted with a self-closing door or doors which shall be, as far
as practicable, kept locked, except when any person is in the
store-room;
(iii) clearly marked with the words "Film Store " ; and
(iv) provided with adequate ventilation.
(b) No store-room shall:
(i) be used for any purpose other than the storage or keeping of
cinematograph film or film waste; or
(ii) contain more than one ton or five hundred and sixty reels of
cinematograph film, whichever is the greater.
10. (a) No open fire or light, nor any smoking materials or matches,
nor anything likely to ignite or decompose cinematograph film, shall
be allowed in any store-room or in any room in which cinematograph
film is manufactured, repaired, manipulated or used.
(b) Suitable arrangements shall be provided for the temporary reception outside such rooms of smoking materials, matches and similar
articles.

118

LEGISLATIVE MEASURES

11. Soldering of cases or packages containing cinematograph film
shall not be done except in a suitable place reserved for that purpose,
and all due precautions shall be taken effectively to prevent the heat
generated during the process from affecting the cinematograph film.
12. In any store-room, or in any room in which cinematograph film
is manufactured, repaired, manipulated or used, the following provisions shall apply:
Provided that nothing in this Regulation shall be deemed to relieve
the occupier of any obligation imposed by the Regulations dated
23 December 1908 * for the generation, transformation, distribution and
use of electrical energy.
(i) There shall be no electric supply fuses or other main service
apparatus.
(ii) No generating plant, switchboard, transformer, motor-generator, converter, fuseboard, fuse, portable resistance, portable
radiator or portable heater, shall be placed therein ; excepting
fuses for individual circuits if of cartridge type and enclosed
in a metal box having the door interlocked with a switch
to break circuit on each pole and connected on the live side
so that the door can be opened only when the switch is "off "
and the fuses are dead.
(iii) All bare conductors such as terminals and commutators of
motors shall be effectively guarded with wire mesh or other
suitable protection. All electric wiring shall be protected
throughout by screwed metal conduit except where slack
wiring or flexible conductors are unavoidable.
(iv) Unavoidable slack wiring shall be as short as possible and
protected where necessary against damage or injury to the
insulation. Flexible conductors shall be heavily insulated and
either protected by tough rubber sheathing or enclosed in
flexible metallic tubing, and proper mechanical fixing of the
metallic tubing or rubber sheathing shall be provided at the
point of entry into the fitting.
(v) All lighting fittings, including those for examination of cinematograph film on the benches and portable lamps, shall be
of substantial construction and shall provide for the effective
enclosure of the lamp and lamp holder and for the secure
attachment of the conductors thereto.
(vi) The covers of switches, including motor starters and regulators, shall be so constructed that the switch handle does
not work through an open aperture. Tumbler type switches
and connector sockets shall be mounted on metal bases,
or on hardwood blocks, or on compressed fibre, affording
adequate protection of the back connections. All switches
for lights in store-rooms shall be outside the store-rooms.
(vii) Lamp holder adaptors shall not be used as connectors. Every
connector socket shall be protected by an enclosed switch to
break circuit on each pole, and if installed after 29 February
1928 shall be so interlocked with the switch that the plug
cannot be inserted or withdrawn whilst the switch is "on ";
and no plug connector shall be so connected that the movable portion can remain live after withdrawal.
1

Statutory Rules and Orders, 1908, No. 1312, p. 340.

GREAT BRITAIN

119

(viii) Resistances, including the heating elements of electric heaters
and radiators, shall be so guarded or enclosed as to prevent
ignition or decomposition of cinematograph film. Such apparatus shall be so constructed that no external part of the
enclosure or guard shall at any time exceed a temperature
of 2120 p . The top of the enclosure or guard shall be sloped
at an angle of not less than 45°.
(ix) All metal work liable to become accidentally electrically
charged shall be efficiently earthed.
(x) Electrical make-and-break contacts on cinematograph film
printing machines shall be so enclosed or arranged as to
render it impossible for them to cause ignition or decomposition of the cinematograph film.
13. A competent person shall be appointed in writing to exercise
supervision with regard to the requirements of these Regulations and
to enforce the observance of them and of any directions given to him
in writing by the occupier with a view to carrying out the Regulations.
14. A printed copy of these Regulations shall be kept posted up
in each room other than a darkroom and immediately outside each
darkroom in a position where it can be easily read by all persons
employed in the room.
PART I I : DUTIES OF PERSONS EMPLOYED

15. No person shall take any open light or flame, or any smoking
materials or matches, or anything likely to ignite or decompose cinematograph film into any store-room or into any room in which cinematograph film is manufactured, repaired, manipulated or used.
16. Every person shall observe such directions as may be given to
him with a view to carrying out these Regulations.
The Cinematograph Film Stripping Regulations, 1928, dated
11 February 1928 *
In pursuance of section 79 of the Factory and Workshop Act, 1901,
I hereby make the following Regulations and direct that they shall
apply to all factories and workshops or parts thereof in which stripping
or drying of cinematograph film (as defined below) is done.
These Regulations, which may be cited as the Cinematograph Film
Stripping Regulations, 1928, shall come into force on 1 March
1928,
from which date the Regulations dated 28 November 1921 2 for the
manufacture, manipulation, and storage of celluloid or any article
wholly or partly made of celluloid, shall cease to apply to the processes
of stripping and drying of cinematograph film.
Provided in the case of any existing factory or workshop the Secretary of State may as regards any requirements of these Regulations
which would involve substantial alterations or additions to the premises, allow the occupier such time as the Secretary of State may
consider reasonable for compliance with the requirement, and subject
to such conditions for securing safety as he may deem necessary.
1

Statutory Rules and Orders, 1928, No. 84.
2 Ibid., 1921, No. 1825, p. 240.

120

LEGISLATIVE MEASURES

Definitions
"Cinematograph film " means any film containing nitrocellulose
or other nitrated product which was intended for use or has been used
in a cinematograph or other similar apparatus.
"Stripping of cinematograph film " means the removal of emulsion
from cinematograph film and includes all unpacking, sorting, unwinding, winding, decolouring, washing and packing of cinematograph
film incidental thereto.
"Drying of cinematograph film " means the drying of cinematograph film from which the emulsion has been removed.
"Fire-resisting material" means:
(a) properly constructed brickwork not less than 4 % inches in
thickness; or
(b) concrete not less than 3 inches in thickness; or
(c) efficiently jointed breeze slabbing not less than 3 inches in
thickness; or
(d) oak or teak not less than 2 inches in thickness; or
(e) glass not less than one-quarter of an inch in thickness in the
centre of which wire mesh is embedded; or
(f) other approved material.
"Store-room" means a room or chamber or similar enclosure in
which cinematograph film is kept or stored, and which satisfies the
requirements hereinafter laid down in regard to store-rooms.
"Approved " means approved in writing by the Chief Inspector
of Factories.
Duties
It shall be the duty of the occupier to observe Part I of these
Regulations. It shall be the duty of all persons employed to observe
Part II of these Regulations.
PART I: DUTIES OF OCCUPIERS

1. All cinematograph film which is not in process of stripping or
drying shall be kept in a store-room.
2. The maximum quantity of cinematograph film in any room
other than a store-room shall not exceed 100 pounds in weight or such
other quantity as may be approved.
3. (a) All scrap cinematograph film arising from stripping or drying
shall be collected at frequent intervals during each day and be placed
in a strong metal receptacle fitted with a self-closing lid, and clearly
marked with the words "Film scrap ".
(b) No material liable to ignite spontaneously nor anything likely
to ignite or decompose cinematograph film shall be placed in the
receptacle.
(c) At the end of each day's work the scrap shall be either transferred to a store-room or removed from the premises.
4. Stripping or drying of cinematograph film shall not be done
in any room unless:
(a) the room is a single-story building or part of a single-story
building ;
(b) the room is separated from any other room or passage by walls
constructed of fire-resisting material;

GREAT BRITAIN

121

(c) all the doors of the room are constructed of fire-resisting
material and are self-closing;
(d) the fittings are, as far as practicable, constructed of fireresisting material;
(e) the furniture and apparatus are so arranged as to afford unimpeded egress for every person in the room in the event of
fire; and
(f) the room is adequately equipped with fire-extinguishing appliances.
5. Adequate means of escape in case of fire shall be provided from
the premises and from every building and every room in which stripping or drying of cinematograph film is done, and the means of escape
shall not be deemed adequate unless:
(i) at least two separate safe exits are provided from every such
building and room and two safe ways of escape from the premises are available for all persons employed in the factory or
workshop; and
(ii) all doors and windows provided in connection with the means
of escape are so arranged as to open outward readily.
Provided that the foregoing provisions shall not apply where the
factory or workshop forms part of a building from all parts of which
means of escape can be1 required under the London Building Acts
(Amendment) Act, 1905 .
6. Drying of cinematograph film shall not be done except under
such conditions as will prevent the cinematograph film from coming
into contact with, or proximity to, any source of heat or heated surface in such a manner as would render the cinematograph film liable
to be ignited or decomposed.
7. The following are the requirements prescribed in regard to
store-rooms :
(a) Every store-room shall be:
(i) a single-story building or part of a single-story building
in an approved situation;
(ii) constructed entirely of fire-resisting material except as
regards the gas relief space required by Regulation 8;
(iii) fitted with a self-closing door or doors which shall be, as
far as practicable, kept locked, except when any person is
in the store-room, and such door or doors shall be capable
of being readily opened from the inside;
(iv) clearly marked with the words "Film Store "; and
(v) provided with adequate ventilation.
(b) No store-room shall:
(i) be used for any purpose other than the storage or keeping
of cinematograph film; or
(ii) contain more than 1 ton of cinematograph film, or such
other quantity as may be approved.
8. (a) In every store-room there shall be a part of a wall or a part
of the roof constructed of ordinary sheet glass lightly fixed in position, so as to provide a gas relief space in the event of an explosion or
fire occurring within the store-room. The area of the gas relief space
shall not be less than 70 sq. inches and not more than 90 sq. inches for
every 500 pounds of cinematograph film that may be stored in the
store-room.
1
5 Edw. 7, c. ccix.

122

LEGISLATIVE MEASURES

(b) The gas relief space shall be protected against external breakage
by a strong wire mesh guard fitted on the outside of the glass.
(c) The position of the gas relief space shall be such that an outburst of flame through the space would not be likely to endanger the
safety of the building or other premises.
9. No premises shall be used for the stripping or drying of cinematograph film, (a) unless and until plans of the premises accompanied
by particulars as to the number of persons to be employed and as to
the arrangements for carrying on the processes and complying with
the requirements of Regulations 4, 5, 6, 7 and 8, have been submitted
and approved; nor (b) otherwise than in accordance with the arrangements so approved; and no material addition shall be subsequently
made to such premises or to the number of persons employed or alteration in the arrangements unless such addition or alteration has been
first approved.
10. (a) No open fire or light, nor any smoking materials or matches,
nor anything likely to ignite or decompose cinematograph film, shall
be allowed in any part of the premises.
(b) Suitable arrangements shall be provided for the temporary reception outside the premises of smoking materials, matches and similar
articles.
11. In any store-room, or in any room in which stripping or drying
of cinematograph film is done, the following provisions shall apply:
Provided that nothing in this Regulation shall be deemed to relieve
the occupier of any obligation imposed by the Regulations dated
23 December 1908 * for the generation, transformation, distribution
and use of electrical energy.
(i) There shall be no electric supply fuses or other main service
apparatus.
(ii) No generating plant, switchboard, transformer, motor-generator, converter, fuseboard, fuse, portable resistance, portable
radiator or portable heater, shall be placed therein ; excepting
fuses for individual circuits if of cartridge type and enclosed
in a metal box having the door interlocked with a switch
to break circuit on each pole and connected on the live side
so that the door can be open only when the switch is "off "
and the fuses are dead.
(iii) All bare conductors such as terminals and commutators of
motors shall be effectively guarded with wire mesh or other
suitable protection. All "electric wiring shall be protected
throughout by screwed metal conduit.
(iv) All lighting fittings shall be of substantial construction and
shall provide for the effective enclosure of the lamp and lamp
holder and for the secure attachment of the conductors
thereto.
(v) The covers of switches, including motor starters and regulators, shall be so constructed that the switch handle does not
work through an open aperture. Tumbler type switches and
. connector sockets shall be mounted on metal bases, or on
hardwood blocks, or on compressed fibre, affording adequate
protection of the back connections. All switches for lights in
store-rooms shall be outside the store-rooms.
1

Statutory Rules and Orders, 1908, No. 1312, p . 340.

GREAT BRITAIN

123

(vi) Lamp holder adaptors shall not be used as connectors. Every
connector socket shall be protected by an enclosed switch to
break circuit on each pole, and if installed after 29 February
1928 shall be so interlocked with the switch that the plug
cannot be inserted or withdrawn whilst the switch is "on ";
and no plug connector shall be so connected that the movable
portion can remain live after withdrawal.
(vii) Resistances, including the heating elements of electric heaters
and radiators, shall be so guarded or enclosed as to prevent
ignition or decomposition of cinematograph film. Such apparatus shall be so constructed that no external part of he
enclosure or guard shall at any time exceed a temperature
of 212° F. The top of the enclosure or guard shall be sloped
at an angle of not less than 45°.
(viii) All metal work liable to become accidentally electrically
charged shall be efficiently earthed.
12. A competent person shall be appointed in writing to exercise
supervision with regard to the requirements of these Regulations and
to enforce the observance of them and of any directions given to him
in writing by the occupier with a view to carrying out the Regulations.
13. A printed copy of these Regulations shall be kept posted up
in each room in which stripping or drying of cinematograph film is done.
PART II: DUTIES OF PERSONS EMPLOYED

14. No person shall take any open light or flame, or any smoking
materials or matches, or anything likely to ignite or decompose cinematograph film into any part of any premises in which stripping or
drying of cinematograph film is done.
15. Every person shall observe such directions as may be given to
him with a view to carrying out these Regulations.

ITALY
There are no special regulations for the manipulation, working
or storage of celluloid applying to the whole country, but each
commune is empowered to issue regulations in accordance with
its requirements. In Milan, for example, celluloid regulations
are contained in the general Fire Prevention Code dated 22 April
1927. There are also safety regulations for stocks of cinematograph films and regulations for the supervision of theatres.
Regulations for the Prevention of Fires in the Commune of Milan
(22 April 1927)
APPENDIX A OF THE REGULATIONS
Celluloid Warehouses and Factories
1. As a general rule, warehouses and factories for celluloid articles
shall:
(a) be situated in places remote from inhabited dwellings;
(b) be built of fire-resisting material;
(c) exhibit outside some clear indication of their special purpose.
2. The exits from the premises in which celluloid is processed and
stored shall be so arranged as to facilitate the egress of the workers
in emergencies.
Where, for special reasons, the exits can only be arranged on one
side of the building, the material being worked shall be stored as far
as possible from the exits and in a place where it will not hamper the
workers' escape.
The exit doors, except sliding doors, shall open outwards.
3. The stocks of celluloid in slabs, sheets or bars shall be kept in
an appropriate building, room or cupboard provided with a conspicuous
notice worded "Stock of celluloid — Inflammable".
The stocks of celluloid shall be so placed as not to impede the egress
of the workers in case of fire in the workshops or anywhere in the vicinity.
4. The quantity of celluloid withdrawn from the stock and taken
into the workshop shall be limited to the minimum required for the
uninterrupted progress of the work.
5. Processing waste shall not be allowed to accumulate on the
workshop floors or tables.
This waste shall be frequently removed, at least twice a day, and
carefully collected in fireproof receptacles bearing the notice "Celluloid
waste — Inflammable ".
6. The celluloid articles processed shall be collected as soon as they
are finished, and immediately carried to the store-place, which shall
be separated from the workshops by fire-resisting walls.
7. Any processing machinery liable to ignite the celluloid by friction shall be placed in separate premises and equipped with suitable
water-cooling appliances.
8. The use of a flame or a brazier shall be avoided as far as possible,
and if either is indispensable, it shall be suitably protected.
Celluloid objects in the course of processing shall also be protected
by suitable guards so .as to prevent their coming into contact with
naked flames or incandescent objects.
The heating shall be by means of furnaces outside the workshops or
store-places, or by other means not entailing the risk of fire.

ITALY

125

9. In workshops, store-places, passage-ways and waiting-rooms,
smoking is strictly prohibited.
Suitable prohibitory notices in large characters shall be affixed in
all premises.
10. Wax seals shall not be used for bags and other packing for
celluloid articles.
11. At all times and in all premises there shall be adequate equipment (pails of water, extinguishers, hydrants) for promptly extinguishing
outbreaks of fire.
12. Some person belonging to the factory or the workshop shall
be made responsible by the firm for the compliance with provisions
of the regulations.
13. A printed copy of the regulations shall be affixed to the doors
of every workshop (locale di lavorazione).
APPENDIX B OF THE REGULATIONS
Safety Regulations for Stocks of Cinematograph Films
1. Premises equipped for the storage, repair or consignment of
cinematograph films, and subsidiary premises, shall be built of fireresisting material and be isolated from stairs, lift shafts, passages and
corridors serving as exits to dwelling-houses, by means of masonry
walls at least 30 cm. thick, in which the indispensable openings may
be allowed provided that they are fitted with fire-resisting locks and
close automatically.
2. Premises for the above-mentioned purposes shall in general, and
preferably, be on the ground floor. "When, owing to the requirements
of the firm, these premises are spread over a number of floors, egress
shall be afforded by a special staircase for the exclusive use of the firm
responsible for the stock. Openings on to the stairs connecting the various
floors shall have, at each floor, fire-resisting locks which open on to
the stairs and are fitted with automatic closing devices. On every
floor, in addition to the opening on to the stairs connecting the various
premises of the firm, there shall be a way out to emergency stairs
leading either to a large courtyard or directly on to the street. In no
case may the storage premises abut directly on the staircase.
3. The premises for the examination and repair of the films shall,
as a general rule, have two or more doors at such distances from one
another as the Fire Prevention Committee (Commissione di prevenzione
incendi) may decide, fitted with fire-resisting locks and opening outwards.
4. Premises for the storage of films shall be separated from other
premises by walls at least 30 cm. thick if of brick, or 20 cm. if of reinforced concrete; and shall be covered by a ceiling made of joists and
solid brick vaulting, or of reinforced concrete at least 15 cm. thick.
These premises shall be provided with one or more air vents in proportion to the size of the store, and these vents shall converge into a
conduit that rises above the roof; or leads outside to a place where,
neither above nor near the discharge outlet, are there any windows
or other openings in dwellings, workshops or store-houses. The entrance
to the premises shall be provided on both sides of the wall with fireresisting doors at least one of which shall remain automatically closed.
In the case of large stocks (over 500 kg.), the rolls of film shall be
suitably distributed over a number of safes made of reinforced concrete
or other fireproof material, and perfectly airtight, so as to prevent any
fire that may break out spreading over the whole stock. Each safe
shall be provided with an automatic fire extinguisher.
5. The premises for storing packing materials shall be separated
from the consignment premises and the other parts of the establishment
by masonry, the openings in which shall be equipped with fire-resisting
doors, having devices for closing them automatically.

126

LEGISLATIVE MEASURES

6. In any premises in which films may be found, even only occasionally, the lighting shall be installed in compliance with the provisions
set out in the specifications of the insurance companies for very dangerous premises. A main switch shall be placed at the entrance to the
premises.
7. The premises, except the store-rooms, may be heated by a system
of hot water piping with outside boilers, or by any other system not
entailing a risk of fire. No means of heating is allowed in the premises
for storing films (in Italy the thermometer rarely falls to 20-30° C. below
zero, the temperature at which celluloid becomes brittle).
8. Every roli containing 150 metres or more of film shall be kept
in a separate metal box covered with a tightly sealed lid, except when
it is necessary to remove the film for repairs.
9. Films, except when required for examination or repairs, shall be
kept in the store premises referred to in section 4.
10. The number of films undergoing examination and repairs at
the same time shall be reduced to the minimum, in no case more than
ten; and as soon as they have been examined and repaired the rolls
shall be put back in the metal boxes and removed to the store-rooms.
11. Every person employed on repairing and examining films shall
have close by a metal receptacle for the collection of film scrap and
waste.
12. In premises that contain films, even occasionally, smoking shall
be strictly prohibited'. At least two notices announcing this prohibition
in large characters shall be affixed to the walls in each of the premises.
13. In each of the premises referred to above there shall be distributed suitable means for promptly extinguishing fires: pails of water,
pails of sand, and woollen or asbestos covers. The store-rooms for the
films shall be provided either with an adequate number of water sprinklers under pressure, workable from outside the premises or with automatic extinguishers, as the Fire Prevention Committee decides.
Also, at suitable places as indicated by the said Committee, there
shall be installed hydrants 40 mm. in diameter, equipped with the
necessary pipes and nozzles, and furnished with connections identical
with those used by the public fire brigade.
14. Premises for storing, repairing, examining, etc., films shall
preferably be situated in buildings of a limited number of stories (not
more than four), and shall be so arranged and provided with exits that
in the case of fire the egress of the workers is not impeded.
Regulations for the Supervision of Theatres (dated 13 December 1923,
with amendements of 28 Mars 1928).

APPENDIX C OF THE REGULATIONS
Special Rules concerning Premises intended for Cinematograph Performances and, generally, Luminous Projections in Theatres and
Other Places of Amusement
General Provisions
In addition to the provisions contained in the Regulations for the
Supervision of Theatres (Regolamenio sulla vigüanza dei teatri), together
with the relevant appendices, and any precautions that the authorities
may prescribe from time to time, the following provisions shall be
observed in any case:
Any person intending to construct or alter premises for cinematographic purposes shall, in the plans referred to in section 7 of the Regulations for the Supervision of Theatres, show to scale the vicinity of the
premises, specify the position and the dimensions of the ticket office
or desk, the control arrangements, the position of the pianoforte or the
orchestra in the auditorium, the arrangement and the number of seats ;

ITALY

127

and include the cross sections required to show the level of the various
parts of the premises as compared with the vicinity, the level of the
seats, and the height of the operator's box above the floor of the auditorium. When the arrangement of the premises is such that all or any
of the doors serving as exits are situated so as to compel the public
to pass through courtyards or passages not forming part of the premises,
the application referred to in the above-mentioned section must be
accompanied by a declaration, in due form and on stamped paper,
by the proprietor of the premises through which the public have to
pass. This declaration must notify full consent to such passage of the
public and contain an undertaking on the signatory's part to keep the
places and areas concerned free from obstacles and to keep open the
street door and any gates in the public's path for the whole of the
time the cinema is open. The gates in question must always open
outwards.
The requirements respecting isolation, as set out in the Regulations
for the Supervision of Theatres, as well as the provisions respecting
grating in windows, may, if the Supervisory Committee (Commissione
di Vigilanza) so decides, be made non-applicable when they are rendered
superfluous by the abundance of exits and their convenient arrangement,
or by other equivalent conditions.
In any case, however, the entrance to the premises or the exit from
them shall be directly on the street and it must be notified that entrance
doors cannot be used as exits.
All the exit doors shall be fitted with simple latches, clearly visible
and fixed at a height of about 1.50 metres from the ground. During
the whole of the time the premises are open to the public these shall
be the only fastenings on the doors.
The upper part of the leaves of the exit doors shall be fitted with
glass which may be coloured but must always be transparent; such
glass may never be covered up by boarding, curtains, etc.
Textile coverings or paper hangings may not be laid over walls.
Lace curtains, drop-curtains, draperies, etc., must be made and
kept non-inflammable.
Except for the musicians, there shall be no movable chairs or other
furniture that can constitute a dangerous obstacle in any part of the
premises to which the public have access.
For the installation or displacement of drinking bars, automatic
distributors, stereoscopes, shooting ranges and the like the previous
consent of the public safety authorities (Autorità di pubblica sicurezza)
shall be required.
Area of, and Exits from, the Waiting-Rooms and Auditorium
If the premises have waiting-rooms the area of these rooms reserved
to the public shall not be less than two-thirds of that taken up by
seats in the auditorium; and in addition to doors giving access to the
auditorium there shall be two independent exits, suitably placed, the
aggregate openings of which shall be not less than 1 metre for every
sixty seats in the auditorium.
When premises have waiting-rooms, the audience shall not be admitted into the auditorium until this has been completely evacuated
by the persons present at the previous performance.
The auditorium, in addition to the doors leading from the waitingrooms, shall have an adequate number of exits suitably placed and
leading to the open, the aggregate clear width of which shall not be less
than 1 metre for every forty seats, benches being reckoned at the rate
of one seat for every 40 cm.
The Supervisory Committee (Commissione di Vigilanza) shall decide
which of the doors shall be considered as emergency exits.

128

LEGISLATIVE MEASURES

Lighting
Lighting in cinematograph theatres shall be furnished exclusively
b y electricity a n d shall be divided into two separate parts, namely:
A. Ordinary lighting.
B . Emergency lighting.
T h e ordinary lighting (A) shall itself be divided into two parts,
namely :
(1) General lighting for t h e auditorium, vestibules, stairs, accessory
services, etc., and in use wholly or partly during t h e performance or
t h e intervals.
(2) Permanent lighting u n d e r red glass by means of lamps installed
a t t h e exit doors a n d bearing t h e inscription " E x i t " , and a t other
places where a white light would impair the projection, b u t sufficient
light is required to show t h e public t h e position of doors and stairs
leading t o t h e street or t h e open.
Emergency lighting (B) shall consist of a given number of noncoloured lamps distributed over t h e auditorium, vestibules, stairs and
other passage-ways, a n d having an intensity such as t o allow the public
to move about easily and reach t h e exits. These lamps which normally
shall not be in use, shall light automatically when the current from the
public distribution system supplying t h e ordinary lighting (A) is cut oñ.
For this purpose t h e lamps forming part of the emergency lighting
shall be supplied from a b a t t e r y of accumulators and provided with a
suitable switch t h a t automatically closes t h e circuit as soon as t h e current
from the public supply system supplying the ordinary lighting (A) is
cut off.
The permanent lighting u n d e r red glass shall be connected t o the
special circuit permanently supplied from the above-mentioned battery
of accumulators, which, like t h e switches for the emergency lighting
and t h e permanent lighting u n d e r red glass, shall b e installed outside
the operator's box.
It shall not be compulsory, b u t it is highly recommendable, for
t h e b a t t e r y of accumulators t o supply t h e projector arc with sufficient
current to enable t h e performance to continue at least half an hour,
even if the current from t h e public supply system is cut off.
Operator's

Box

The box or compartment containing the projector shall be constructed
of incombustible material.
It shall be outside t h e auditorium and not communicate with it in
any way, except b y t h e observation ports and the aperture for the
beam of light. Its internal dimensions shall not be less t h a n 2.20 metres
on each side and in addition it shall be well and adequately ventilated
by means of air ducts, possibly leading from outside.
The windows and ports of the box, including those for observation,
and only excepting t h a t allowing t h e passage of the beam of light for
the projections, shall be fitted with metallic mesh.
The stairs giving access t o t h e box shall be built of incombustible
material, fitted with hand-rails and, as far as possible, placed out of
the public's sight and way.
The box door shall open outwards and be fitted with a simple spring
catch.
Electrical

Equipment

Electrical equipment shall comply with the provisions of the current
Regulations for the Supervision of Theatres, and the relevant appendices,
as well as t h e following special regulations:
(a) All switches, fuses, resistances, transformers, potentiometers,
etc., shall be protected.

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129

(b) Ordinarily, for branch lines inside premises, no fuse box, as
referred to in section 16 of Appendix A, shall serve for more than three
lamps.
(c) The operator's box shall be well lighted, and exclusively by
fixed incandescent electric lamps.
(d) The switch board in the box shall have, in the projector circuit
a voltmeter and an ammeter, apart from any other apparatus that
the Supervisory Committee may consider necessary.
(e) With a view to giving accessibility to the switchboards, as
referred to in section 8 of Appendix A, all switchboards and distribution
boards in the premises may be fixed directly to the wall provided that
the conductors and connections are on the front. On these switchboards
no bare metal conductors shall be allowed for connections or other
purposes unless they are completely protected by glass or stout perforated plates fitted at an adequate distance from the conductors.
Type of Projector Light and Lamps
For the projector light use may not be made of paraffin or acetylene
lamps or any other lamps that may be considered dangerous by the
Supervisory Committee.
The projector lamp case, in addition to being made of incombustible
material and satisfying the requirements of section 19 of Appendix A
of the Regulations for the Supervision of Theatres, must be equipped
not only with an automatic shutting-off device between the lamp and
the condenser but also with a metallic shutter that can be easily worked
from the outside and drops in case of accident.
In the projector, between the condenser and the film, there shall
always be kept a basin filled with a saturated aqueous solution of rock
alum; and in the operator's box there shall always be at least two such
basins, one being used in turn with that mentioned above, and the
other being kept in reserve.
"When the condenser is a glass globe filled with water it may replace
the basin referred to above, but use shall then always be made of
water saturated with rock alum; and in the operator's box at least
two spare globes shall be kept in readiness.
The projector shall be provided with devices which, if the film stops
or breaks, immediately extinguish the projector light, at the same time
stopping the motor unwinding the film, and, lastly, automatically and
instantaneously turning on all the ordinary lighting of the auditorium
and accessory services.
Precautions with regard to Films
Both on the paying-off spool and on the winding-on spool the film
shall be protected by a metal box of the well-known Pathé type, or by
any other appliance that the Committee may consider equally efficacious.
The boxes shall have stout sides without welds, and should be easy
to handle.
The said safety appliances shall be in use for all manipulations of
the film.
When the distance between the two safety boxes exceeds 50 cm.,
the intervening length of film shall be effectively protected, leaving
uncovered in the projector only the strip through which the beam of
light has to pass.
Operating Regulations
The film may be unwound by an electric motor, which must be installed in compliance with the safety rules drawn up for electric lighting
systems.
While the premises are open to the public, there shall be kept in
them only the films required for the day's performance, together with

130

LEGISLATIVE

MEASURES

not more than two reserve films, but in any case not more than 30 kg.
of film in all.
The films shall be kept in fireproof containers provided with good
fastenings and may not be left outside the containers except during the
time strictly necessary for their use; nor may the containers be left
open unnecessarily.
Tn the box there shall be kept within reach at least one pail of water
on each side of the projector.
It is very strictly prohibited to smoke either in the operator's box
or in the auditorium; breach of this rule may entail the revocation of
the occupier's licence.
In the box there shall always be two operators, the duties of one
being confined to ensuring that all is in good order.
In the auditorium there shall be no standing room, and the public
shall be so informed by means of suitable notices in the printed bills
announcing the performances, and in the programmes, and also by an
adequate number of notices posted up both in the auditorium and the
waiting-rooms and bearing in legible characters the words: "By order
of the authorities, the public are absolutely prohibited from loitering
in the passages ".
The same notices shall state the number of seats, which number
will be fixed, as regards the auditorium, by the Supervisory Committee.
With reference to the provisions of the preceding section respecting
the auditorium, there may never be more spectators than the number
of seats, and when this is likely to occur the sale of tickets should cease
until at least a part of the audience has left the auditorium.
Except in the premises referred to below, cinematograph performances are prohibited in public undertakings selling or serving refreshments, no matter what the type of undertaking, unless the premises
are entirely open or the performance is in the open air.
In variety theatres and other places of amusement, provided that
they are on the ground floor, even if refreshments are served, performances may be given which include cinematographic projections; but
these, when not in the open air, may not constitute more than an ordinary
turn (numero) of the variety show, and must be subject to a special
licence, carrying with it an obligation to have a fireman present in the
operator's box.
In theatres in which members of the public safety force or firemen
are ordinarily on duty, the programme may consist entirely of cinematograph films, and consequently these premises may be adapted, even
only temporarily, for continuous cinematograph performances.
In such cases, however, the use, even partial, of the boxes, galleries,
etc., shall as a rule, be prohibited. Exemption from this provision may
be given by the public safety authorities after consulting the Supervisory Committee.
The exemption must be in writing.
In this case, the regulations applying to premises intended exclusively
for cinematograph performances shall apply indiscriminately to the
theatre, with the exception only of the provision concerning the position
of the operator's box, which may be inside the auditorium, provided
that:
(a) it does not in any way hinder the public from leaving or even
merely moving about;
(b) the position is such that the public cannot see inside.
The Supervisory Committee shall be consulted as to the best position
for the box.
The constant presence of a fireman in the operator's box shall be
compulsory while the public has access to the theatre for the performance.
All the provisions in Appendix A of the Regulations for the Supervision of Theatres shall be strictly complied with.

ITALY

131

In the above case the written application for the inspection of the
premises should reach the public safety authorities not later than three
days before the date proposed for the first performance.
The regulations relating to cinematograph performances must be
affixed in the operator's box.
No alterations to the premises, or in any detail of their arrangement, or again, in the plant or apparatus, may be effected without
previously obtaining the consent of the public safety authorities, to
whom a special application, setting out the alterations desired, must
be made.
Such application must be accompanied by suitable drawings to a
scale of not less than 1: 200.
Cinematograph Performances in Wooden Sheds
On the occasion of fairs, exhibitions, and the like, authority may be
given for cinematograph shows in wooden theatres or sheds, when, in
addition to satisfying all the conditions laid down in the Regulations
for the supervision of theatres, and any other regulations that the
authorities may make from time to time, the following rules are observed:
(a) The projector must always be outside the auditorium, in a
metallic box or compartment conforming to all the provisions of the
preceding sections.
(b) All the switches, fuses, potentiometers, transformers, resistances,
etc., must be protected.
(c) The electric conductors may be mounted on simple insulators
provided that they offer no danger of contact one with another or with
combustible materials.
(d) The apparatus and equipment required for the generation or
transformation of electric current shall be outside the premises and so
placed and guarded as to avoid any danger to the public.

JAPAN
In J a p a n t h e F a c t o r y Act, 1911, is being applied, regardless
of t h e number of employees, t o all factories and workshops in
which celluloid is manufactured or celluloid goods are subjected
t o heat t r e a t m e n t or sawing. Such work is also subject to the
Regulations on Safety a n d Health, dated 20 J u n e 1929, and
more particularly t o sections 2 1 , 23 and 27 of these Regulations.
Regulations No. 24 of the Department of the Interior, dated 20 June 1929
21. In places where explosive, combustible or inflammable
substances are manufactured, handled or stored, places where gases,
fumes or dust are generated and are liable to cause explosions, or any
other places where there is serious risk of fire, the use of fire and
the emission of sparks shall be prohibited, except in cases where
this is indispensable for the performance of work; provided that this
rule shall not apply to the use of safety lamps, incandescent electric
lamps or any other apparatus which is not dangerous.
Suitable notices shall be posted in the places mentioned in the
preceding paragraph to prohibit smoking or the use of any fire other
than that which is indispensable for the performance of work in those
places.
23. Workrooms in which explosive, combustible or inflammable
substances are manufactured or handled and those in which fifty or
more persons are regularly employed shall be provided with two or
more suitable exits, to ensure that in the event of fire or other emergency the persons employed therein may have easy access to places
of safety.
In cases where ten or more persons are regularly employed on the
first floor or higher, two or more staircases at suitable points shall
be provided between every two floors, in order to afford easy access
to safe places outside the building.
In cases where fifty or more persons are regularly employed on
the first floor or higher, the staircases mentioned in the preceding
paragraph shall fulfil the following conditions:
(1) The width of a stair shall not be less than 7 sun 1 and the rise
shall not be more than 7 sun.
(2) The angle at which the staircase rises shall not be more than 40°.
(3) If the length of the staircase exceeds 12 shaku 2 , it shall be
provided with a landing at least every 12 shaku.
(4) The inside width of the stairs shall not be less than 3.5 shaku.
(5) No circular turns shall be used in the stairway.
(6) The staircase shall be provided with handrails not less than
2.7 shaku high.
(7) A space at least 5.7 shaku high shall be left clear above the
whole stairway.
1
1 sun = 1.19303 inches.
2
1 shaku = 0.994194 feet.

JAPAN

133

The provisions of the three preceding paragraphs shall not apply
in cases where they are unnecessary owing to the nature of the work,
construction, equipment, etc.; of the building, nor to buildings which
were constructed before the coming into operation of these Regulations and in which the conditions do not admit of the application
of the said paragraphs, provided that this is approved by the prefectural governor.
27. There shall be no admittance except on business to the following places, and notices to that effect shall be posted there:
(1) Places in which explosive, combustible or inflammable substances are manufactured, handled or stored.
(2) Places in which poisonous drugs or substances or any other
injurious substances are manufactured or handled.
(3) Places in which gases, fumes or dust are generated, and are
injurious to the health of workers.
(4) Places in which large quantities of very hot substances are
handled.
A person shall not without permission enter any place to which
admittance is prohibited under the preceding paragraph.
In respect of work carried on in places mentioned in the first
paragraph of this section, the prefectural governor may prohibit the
undertaking of any other kind of work, or may order any other
necessary measures.

SWEDEN
In Sweden t h e manufacture of raw celluloid and films from
nitrocellulose is considered as manufacture of explosive goods
of Class I, and is subject, as such, t o the provisions of t h e Regulations on t h e Manufacture of Explosive Substances, dated
18 May 1928.
The storage, handling, etc., of cinematograph and X-ray
films manufactured from nitrocellulose is covered b y t h e provisions of Royal Order N o . 178, dated 3 J u n e 1932; t h e performance of cinematograph films and t h e erection and installation
of cinema theatres are covered b y the provisions of t h e Royal
Order No. 179, of t h e same date.
Royal Order to issue Certain Regulations concerning Films,
dated 3 June 1932 *'
CHAPTER I:

SCOPE, ETC.

1.
(1) For the purposes of the present Order, by "films " shall be
understood highly inflammable substances containing nitrocellulose
and intended either for the production and projection of cinematograph pictures (cinematograph films) or for X-ray photography and
activities in connection therewith (X-ray films).
(2) The provisions of the present Order shall also apply to film
waste and condemned films, but their possession, storage and handling
may be regulated, instead of by the provisions of Chapter II of the
present Order, by the relevant parts of the provisions for Class I
explosives contained in Chapter IV of the Regulations on Explosive
Substances of 18 May 1928.
(3) The provisions of Chapter II, with the exception of section 16,
shall not apply to quantities of film not exceeding 5 kg.
(4) The provisions of Chapter III shall not apply to unexposed
films.
(5) Except as regards projections under section 19, subsection
(1), the special provisions hereby enacted shall apply to the possession,
storage and handling of cinematograph films in connection with the
projection of cinematograph pictures.
(6) If there is any doubt as to the extent to which any substance
is covered by the provisions of the present Order, it shall be for the
Board of Trade, after consultation with the Explosives Inspectorate,
to issue regulations on the subject.
2.
(1) Fireproof structural parts shall mean such structural parts
as in the event of a fire and the ensuing spraying of water possess
adequate solidity and are at least as resistant as a wall ôf burnt brick,
1

Svensk Författningssamling, No. 178 of 9 June 1932.

SWEDEN

135

of the thickness required for the purpose in question, but at least
10 cm., and resting on a substructure affording equivalent security
against fire.
Fire-resisting structural parts shall mean such non-fireproof
structural parts as, in the event of a fire and the ensuing spraying of
water, possess at least the same resistance as a boarded wall, with
fillets, reeding and plaster on both sides. Reeding and plaster, or
other facing affording equivalent security against fire on only one
side, is hereinafter called fire-resisting facing.
Flame-obstructing structural parts shall mean such structural
parts in wood or other combustible materials which, in the event
of a fire, are protected against ignition and spread of the fire along
their surface at least as long as a boarded wall covered on both sides
with asbestos-cement slabs 4 mm. thick of sufficiently good quality.
Such slabs of the said thickness and quality, or facings affording
equivalent security against fire on only one side are called flameobstructing facing.
It shall be for the Government Material Testing Institute, after
inspection and suitable testing, to decide to what extent structural
parts comply with the above requirements.
(2) By locks shall be understood rooms provided with doors, lying
along the way of escape and serving to prevent the spread of smoke
or fire. The doors shall be at least fire-resisting and open outwards
from the lock.
CHAPTER II:

POSSESSION, STORAGE AND HANDLING

General Provisions
3.
(1) For the possession of films in quantities over 5 but under
45 kg. (small depots), shall be required a notification, and for quantities
over 45 kg. (large depots), an authorisation as specified in the more
detailed provisions hereinafter enacted. Large depots shall not
contain more than 30,000 kg.
(2) Special rooms which communicate with cinematograph film
depots and in which films are subjected to special treatment such as
developing, drying and cutting, or films are otherwise prepared for
projection, are, together with operator's boxes, consignment rooms
and store-rooms, hereinafter called film laboratories or film offices.
(3) The department of a hospital in which X-ray films are stored
and photographs taken with such films, and in which films are subjected to certain treatment such as developing, drying or testing, is,
together with the film depot, hereinafter called the X-ray department.
(4) In buildings in which quantities of film above 15 kg. are stored,
there shall be no equipment or storage presenting fire risks unless
special precautions are taken for such equipment or storage.
4.
(1) Notification of small film depots shall be made to the police
authorities of the locality in which films are to be stored, and in
localities to which the Fire Regulations apply, also to the chief of
the fire brigade. The storage of X-ray films in hospitals shall also be

136

LEGISLATIVE MEASURES

notified to the Medical Board. In the notification shall be mentioned :
(a) the position of the film depot;
(b) the quantity to be stored;
(c) the time of storage.
(2) Small stocks shall be kept in cupboards or drawers made of
oak at least 25 mm. thick, or other material equally resistant to fire.
The cupboard or drawer shall not be placed in living rooms and,
except when films are actually being put in or taken out, shall always
be kept closed.
5.
(1) In the case of X-ray films in hospitals, applications for permission to erect large depots shall be submitted to the Medical Board,
and in other cases to the provincial Government. In the application
shall be mentioned:
(a) the place where the depot is to be erected;
(b) the maximum quantity of film that the applicant intends to
store at any one time;
(c) the nature of the building materials and the structure of the
building in which the depot is to be erected, the heating,
lighting and ventilation equipment of the store-rooms, and
the precautions planned.
The application shall be accompanied by the following documents
in duplicate: drawings with a description, and a site plan showing
the position of the building.
(2) The views of the local police authorities and, in localities
where Fire Regulations apply, those of the chief of the fire-brigade,
shall be obtained on the application. For depots holding more than
3,000 kg., the views of the Explosives Inspectorate shall also be obtained. If a licence is issued, it shall contain provisions on all matters
which, under the present Order, have to be mentioned in the application, together with any other special conditions and rules which may
be found necessary by the authorities issuing the licence.
One copy of the drawings submitted and approved, bearing an
indication of approval, shall be attached to the licence; the other
shall be deposited with the authorities issuing the licence.
(3) Rooms equipped to serve as large depots shall not be taken
into use until approved, after inspection, by the authorities issuing
the licence for the storage of films. At such inspections, the local
police authorities, and in localities where the Fire Regulations apply,
the chief of the fire-brigade, shall be represented. If the quantities
to be stored exceed 3,000 kg., the Explosives Inspectorate shall also
be represented at inspections when this is considered necessary.
The cost of the inspection shall be borne by the occupier of the
depot to the amount fixed by the authorities mentioned in subsection (1).
6.
(1) Provided that the quantities to be stored do not exceed
150 kg., large depots may be erected subject to the following conditions :
(a) From the attic or the floor on which the store-rooms lie,
and from the floors above, at least two ways of escape independent
of each other shall lead to the ground floor.

SWEDEN

137

(b) The store-rooms, which shall not be living rooms, shall be
securely separated from living rooms and from ducts leading to other
rooms in the building in such a manner that fire and smoke cannot
penetrate to them.
(c) The walls and ceilings of the store-rooms shall be faced with
at least fire-resisting materials and the doors leading to these rooms
shall open inwards, close automatically and be at least fire-resisting.
(d) The films shall be stored in fire-resisting cupboards of a type
approved by the Government Material Testing Institute. Each
cupboard shall be provided with an independent ventilation duct
that is at least fire-resisting and has the outlet into the open so arranged
that there is no danger of smoke or fire penetrating into the other
parts of the building.
(e) Except when films are actually being put in or taken out,
the cupboard shall be kept closed.
Stocks to the amounts mentioned in the first paragraph of this
subsection shall not be kept in basements.
(2) When depots falling under the provisions of subsection (1)
are erected in hospital buildings serving to accommodate patients,
then without prejudice to the said provisions, the store-rooms shall
be provided with floors of oak or other material affording equal
security against fire, and a lock that is at least fire-resisting.
7.
(1) At the top of buildings whose outside walls, supporting
structures, intermediate ceilings and stairs are fireproof (fireproof
buildings), in special store-rooms installed under the provisions of
subsection (2), large stocks up to 3,000 kg. may be stored, either in
the attic, or if no properly built attic exists, on the top floor, subject
to compliance with the following provisions:
(a) From the floor on which the store-rooms lie at least two sets
of stairs independent of each other, one of which may be outside iron
stairs, shall lead to the ground floor, and stairs inside the building
shall be in staircases.
(b) The store-rooms shall be suitably placed from the standpoint
of egress from the building and in relation to the stairs.
(c) On the floor on which the store-rooms lie there shall be no
living-room, unless such room and its way of escape are securely
separated from the store-rooms and their ways of escape in such a
manner that smoke and fire cannot penetrate.
(d) Air ducts, etc., from other premises in the building shall be
securely separated from the store-room in such a manner that smoke
and fire cannot penetrate.
(e) Not more than 1,500 kg. of film shall be stored in any one
store-room.
(2) As regards the nature of the store-rooms referred to in paragraph 1, the following provisions shall be complied with:
(a) The walls, ceiling and floor of the store-room, and the duct
leading to the explosion relief valve shall be fireproof and have a
resistance of 1,000 kg. per sq. metre to inside pressure.
(b) The store-room shall be provided with a separate duct having
a clear cross-section of at least 0.3 sq. metre, leading through the roof,
projecting at least 1 metre above the roof ridge and otherwise high
enough in relation to neighbouring buildings. The top of the duct shall
be slanting and covered with a galvanised metal sheet acting as an

138

LEGISLATIVE MEASURES

explosion relief valve, or with wired glass or other glass of equal
strength. The metal sheet or the glass as the case may be shall be
fastened with putty.
(c) The duct mentioned under (a) and (b) shall be provided with
two gratings (spark catchers) consisting of iron bars 5 mm. thick
and 50 mm. wide at clear intervals of 20 mm. one from another.
The said gratings shall be fitted.at least 2 metres one from another
in such a way that the bars of the upper grating are at right angles
to those of the lower.
(d) The duct shall be separated by a distance of at least 25 cm.
reckoned from the inner surface, and in a fire-proof manner, from all
wooden parts.
(e) There shall be provided for the ventilation of the store-room
both an opening fitted with mesh between the duct gratings and a
fresh-air vent installed fireproof, fitted with a mesh, and leading
directly into the open.
(/") The store-room shall be provided with a lock of which the
walls, ceiling and floor shall be fire-proof.
(g) No common lock shall be installed for two or more store-rooms.
(h) Apart from the explosion relief valve, there shall be no window.
8.
Provided that the circumstances are specially favourable with
regard to the position and height of a fireproof building in relation
to other buildings, and with regard to the position of the store-rooms
in relation to the ways of escape from the building, then under the
conditions specified in section 7, at the top of such building, either
in the attic, or where no properly built attic exists, on the top floor,
a large depot for a quantity of film not exceeding 6,000 kg. may be
installed, subject to compliance with the following provisions:
(a) There shall be no living-rooms in the building other than that
for the doorkeeper and furnaceman.
(b) Each store-room shall be equipped with a properly constructed
automatic sprinkler plant.
9.
(1) Depots for quantities of film exceeding 3,000 kg. shall be
erected in fireproof buildings. In cases not dealt with in section 8
the following provisions shall be complied with:
(a) The building shall be at a clear distance of at least 9 metres
from other buildings and so situated that it can involve no special
danger for the neighbourhood. The authorities issuing the permit
for the erection of the film depot may, however, after consulting
the Explosives Inspectorate, approve exceptions in regard to the
said distance.
(¿>) The building shall exclusively serve for the storage of films
or as a film laboratory, film office or X-ray department.
(c) Rooms in which fireplaces are installed shall be separated
in a fireproof manner from the other parts of the building.
(d) There shall be no living-room in the building.
(e) Above a floor on which store-rooms are installed there shall
be no workrooms.
(f) The whole building shall be provided with a properly installed
automatic sprinkler plant.

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139

(g) The films shall be stored in special store-rooms complying
with the requirements of section 7, subsection (2).
(ft) Not more than 1,500 kg. of film shall be stored in any one
store-room.
(2) When depots falling under subsection (1) are installed in a
hospital building, the said building may, where necessary, communicate on one floor with a building in which patients are accommodated,
by a special corridor equipped with at least fire-resisting doors. The
said corridor shall, however, not be at the same height as or higher
than the store-room.
10.
(1) The heating of rooms in which films are stored or handled
shall be effected only by hot-water systems or electric radiators of a
type approved by the Board of Trade.
The radiators and other component parts required for heating,
together with the pipes leading to them, shall be so protected that
films cannot be laid on or by them. On the radiators, or within 25 cm.
of them, no shelves shall be fitted for the deposit of films. The wiring
required for the electric radiators shall be laid in compliance with the
provisions of section 11 respecting electric-light wiring.
(2) Suitable measures shall be taken to prevent films from being
exposed to the action of the sun or any other source of heat.
11.
(1) If there is artificial lighting in rooms in which films are stored
or handled, electric filament lamps shall be used for this purpose.
The lamps shall be provided with protective globes.
(2) Switches, fuses, resistances and other electrical apparatus
shall be placed outside the room, or so made and installed that they
cannot cause the films to ignite.
(3) Motors shall be enclosed.
(4) In store-rooms and other storage rooms, the electric wiring
shall be fixed in position and installed as armoured lead-covered
rubber cable or enclosed in tubing.
(5) In rooms other than those mentioned in subsection (4) lamps,
motors and radiators together with their wiring shall as far as possible
be fixed in position. Movable equipment shall be so made that it is
as safe as required.
(6) For the rest, the relevant parts of existing or future general
regulations concerning the construction of electrical equipment shall
be complied with.
12.
Ways of escape from rooms in which films are stored or handled
shall be easily accessible and kept clear of inflammable objects and
obstructions.
13.
Smoking and the use of matches or fire in any other form shall
be prohibited in rooms in which films are stored or handled. Notices
to this effect shall be conspicuously affixed on the outside of the door
leading to the room and at other suitable places in or by the room.
14.
A sufficient number of bucket-pumps or pails, kept full of water,
or chemical fire-extinguishers of a type approved for this purpose by

140

LEGISLATIVE MEASURES

the Government Material Testing Institute, shall be provided at
suitable places inside or outside rooms in which films are stored or
handled. The places at which these appliances stand shall be indicated
by the words: "Fire extinguisher ".
15.
Apart from the above provisions, rooms for large stocks shall
comply with the following provisions:
(a) In such rooms there shall be no other goods than films and
the necessary packing for them.
(b) On the outside door shall be a notice specifying the maximum
quantity of film storable in the rooms at any one time.
(c) If there is a fire-brigade, at a suitable place in or by the
rooms there shall be affixed a notice indicating the nearest fire alarm
or other means of summoning the fire-brigade.
(d) The doors of the store-rooms shall be kept closed except when
films are actually being put in or taken out.
16.
While in storage exposed cinematograph films shall be kept in
containers of wood or strong cardboard, Exposed X-ray films shall
be kept in paper envelopes.
Special Provisions for Film Laboratories and Film Offices
17.
(1) Apart from the particulars prescribed in section 5, subsection
(1), applications for a licence to store films in film laboratories or film
offices shall contain the following particulars:
(a) The maximum quantities of film that the applicant intends
to deal with or handle daily, and the quantities likely to be present
in each workroom at any one time.
(b) The number of persons to be employed simultaneously in
each workroom.
(2) The provisions of section 5, subsection (3), concerning approval
of rooms for the storage of films shall also apply to other rooms in
film laboratories and film offices.
(3) In rooms of film laboratories or film offices in which films
are subjected to treatment or are otherwise handled, in so far as the
provisions of subsection 4 do not prescribe otherwise, the walls and
the ceiling shall be faced with at least fire-resisting material. The
doors of such rooms shall close automatically, open outwards and be
at least fire-resisting.
(4) Film laboratories or film offices in which there are more than
150 kg. of film shall be separated in a fireproof manner from the
other buildings, but the doors need be only fire-resisting. Rooms in
which films are brought for consignment (packing rooms) shall be
separated in a fireproof manner from the other rooms of the film
laboratory or film office.
(5) It shall be prohibited to bring cinematograph films for treatment or other handling into rooms other than those specially equipped
for the purpose.

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141

18.
(1) In rooms in which cinematograph films are tested or examined
(film-testing rooms), not more than three persons shall be employed
simultaneously.
(2) In film-testing rooms there shall not be more than 45 kg.
of film at any one time. Notices to this effect shall be painted on the
outside of the doors with the following wording for example: "Filmtesting room for not more than 45 kg. of film".
(3) For the storage of film waste there shall be a tightly-shutting
container by every workplace in a film-testing room.
(4) Every day at the close of work the films in the film-testing
rooms shall be taken to the room assigned for their storage; when,
however, it is necessary to keep films in the film-testing room after
the close of work, this may be allowed by way of exception if the
room is kept locked and the films stored in cupboards or containers
of oak or other material affording equivalent security against fire.
19.
(1) The projection of films in film laboratories or film offices shall
only take place in an operator's box specially assigned for the purpose.
(2) In the operator's box there shall not be more than 30 kg. of
film at any time. A notice to this effect shall be painted on the outside
of the door.
Films that are not actually in the projector or on the winding
mechanism shall be kept in a container of oak or other material
affording equivalent security against fire. The container shall have
a compartment for each reel of film and each compartment shall have
a separate tightly closing and self-locking lid.
(3) The projectors shall be provided with adequately safe fireproof drums (brandkassetter).
20.
In film-packing rooms there shall not be more film at any time
than the amount required for a specific consignment. A notice to
this effect shall be painted outside the door, e.g. the words: "Filmpacking room: films only to be brought in for consignment ".
Special Provisions for X-Ray Departments and Hospitals, etc.
21.
(1) The walls and ceilings of X-ray department rooms in which
photographs are taken shall have at least a flame-obstructing facing ;
walls and ceilings of rooms in which films are subjected to certain
treatment such as developing, drying or testing, shall have at least
a fire-resisting facing.
(2) Doors and shutters leading from other parts of the building
to the rooms mentioned in subsection (1) shall have no glass filling,
but shall be made in one piece, close automatically and fit tightly
in rabbets. Nevertheless, wired glass may be fitted in doors and
shutters when this is necessary, and doors leading to rooms in which
photographs are taken may be allowed even if not closing automatically
and not fitting tightly into rabbets. The doors shall open inwards,
i.e. towards the X-ray department.

142

LEGISLATIVE

MEASURES

(3) The provisions of section 5, subsection (3), concerning the
approval of rooms for the storage of films shall also apply to other
rooms in the X-ray department.
(4) Without prejudice to the provisions of section 10, subsection
(1), in X-ray departments steam may be used for heating rooms in
which photographs are taken.
22.
As regards the maximum quantity of X-ray films that may be
kept in the rooms mentioned under (a) to (d) below, the following
provisions shall be complied with:
(a) In rooms in .which photographs are taken there shall be only
films in boxes or special packing to an amount not exceeding 10 kg.,
together with another 2 kg. to be kept in drawers of oak or other
material affording equivalent security against fire.
(b) In rooms used for developing or drying there shall be only
such quantities as are actually bein^ treated.
(c) In rooms in which films are examined there shall be only such
quantities as are absolutely necessary for the work.
(d) In rooms assigned for the treatment of patients there shall
be films only during the doctor's visit to the department, in question,
and only to such an amount as is absolutely indispensable for the
treatment of the patients actually present. After the doctor's visit
the' films shall be taken to the room assigned for their storage. Nevertheless, a quantity not exceeding 2 kg. may, by way of exception,
be stored in dependent rooms of the sick wards, but only in a closed
cupboard or in a closed drawer of oak or other material affording
equivalent security against fire.
23.
(1) X-ray films shall not be dried at a temperature above 40° C.
The source of heating used for drying shall be so protected that the
film cannot come into contact with it.
(2) In the testing of films heating up to a temperature at which
the film catches alight shall be precluded.
(3) The prohibition contained in section 13 shall not prevent
such use of fire as is required in a hospital for the patients' welfare.
CHAPTER I I I :

TRANSPORT

24.
(1) For transport purposes the films shall be packed in impervious
cases with tightly closing and well-fastened lids, or other wooden
containers, or durable cardboard boxes. The last-mentioned type of
packing shall, however, not be employed for consignment by post
unless the weight of the goods does not exceed 0.5 kg. Film waste
and condemned film may also be packed in strong impervious envelopes or sacks of unbleached linen or jute fabric. When film waste
or condemned film is being transported in open vehicles the waste
or film shall be covered with an awning or the like.
Other safe types of packing may also be employed if approved
by the Board of Trade after consultation with the Explosives Inspectorate.

SWEDEN

143

(2) The contents of each package shall be indicated by attaching
coloured labels or in some other conspicuous manner. If the contents
are film waste or condemned film the words "Film waste " shall be
used for this purpose; and otherwise the word "Film ", with the addition, in all cases, of the word" Inflammable ". Further the consignor's
name shall appear on the package.
(3) If the contents are not film waste or condemned film the
weight of a single package shall not exceed 50 kg.
25.
During transport the packages shall not be placed in the immediate
vicinity of heating appliances. In wagons, or other means of transport,
or in aircraft used for regular passenger traffic, they shall not be so
placed that if the films catch alight the exit is cut off.
26.
In addition to the provisions of sections 24 and 25, transport by
post shall be subject to the relevant provisions of the general Post
Act and the schedules of postal rates.
27.
(1) On the railways films shall only be transported in closed
wagons, and small consignments of film waste only by slow goods
train.
(2) On waybills (express goods waybills) for film waste or condemned film the nature of the goods shall be designated by the words
"Film waste". Otherwise the word " F i l m " shall be used, and, in
all cases, the word " Inflammable " shall be added. Both terms shall
be in red and underlined in red.
(3) In addition to the provisions of the present section and of
sections 24 and 25, transport by rail shall be subject to the relevant
provisions of the Railway Traffic Act and the relevant rate schedules.
(4) Traffic to or from countries parties to the International
Convention on the Transport of Goods by Rail shall be subject to the
provisions of the Convention.
28.
In the case of consignment by sea the bill of lading shall mention
the number, type, contents, net weight and gross weight, of the
packages. If the contents are film waste or condemned film, they
shall be designated by the words "Film waste " ; otherwise the word
"Film " shall be used and in all cases the word "Inflammable " shall
be added. Both terms shall be in red and underUned in red. On the
bill of lading the consignor shall declare that the inscription on the
packages is a true description of the contents and that the packing
complies with the regulations in force. No goods other than films
shall be mentioned on the bill of lading.

CHAPTER IV:

PENAL PROVISIONS, ETC.

29.
(1) Anyone who, without being so entitled, is proved to possess
films in greater quantities than, under section 3 subsection (1), are
allowed to be stored without a licence or notification; or anyone who,

144

LEGISLATIVE

MEASURES

having been granted a licence for the storage of films, or having notified
such storage, is in possession of larger quantities of film than are
allowed under the said licence or notification; or anyone who stores
films of a type or in a manner other than that mentioned in the licence,
or anyone who attempts to consign films by giving false particulars
or failing to notify the nature of the consignment, shall be liable to
a fine at least equal to five days' income.
(2) Anyone who, in ways other than those mentioned in subsection (1), offends against the regulations of Chapter. II, or any
special regulations issued by the competent authorities under the
provisions of the said Chapter, or any consignor who, in ways other
than those mentioned in subsection (1), offends against the provisions
of Chapter II concerning the transport of films, or any regulations
issued by the competent authorities under the provisions of the said
Chapter, shall be liable to a fine of from 5 to 300 kronor.
30.
Anyone who, while being prosecuted for an offence against the
present Order, continues the same offence shall, if legally convicted,
be liable for the penalty provided for such offence in respect of each
summons.
If an offence that would otherwise be punishable under the penal
)rovisions of the present Order is punishable under the general criminal
aw, the provisions of the present Order shall not apply.

Í

31.
Proceedings in respect of prosecutions for breaches of the provisions of the present Order shall be heard in the public courts and
conducted by the public prosecutor.
32.
Fines inflicted under the present Order shall accrue to the Crown.
If the full payment of fines appears impossible they shall be commuted
under the general criminal law.
(1) The present Order shall come into force on 1 January 1933.
(2) In cases in which, under the present Order, a licence is required
for the storage of a certain quantity of film, it will be for the person
who is in possession of such quantity at the entry into force of the
present Order and who desires to continue in possession thereof to
submit the application prescribed by the provisions of the present
Order within three months of its coming into force.
(3) The provisions of paragraph (2) shall apply, mutatis mutandis,
in cases in which, under the present Order, notification is required for
the storage of a certain quantity of film.
(4) Buildings for the storage of more than 3,000 kg. of film and
erected before the entry into force of the present Order shall be excepted
from the provisions of section 9, subsection (1) (a), respecting distances.
(5) In buildings, store-rooms and other rooms, existing at the entry
into force of the present Order, any necessary alterations required under
sections 6-11, section 17, subsections (3) and (4), and section 21, subsections (1) and (2), shall be carried out within not more than three years
of the entry into force of the present Order. For the said buildings and
rooms the authorities competent to issue licences for the storage of

145

SWEDEN

films may, in exceptional cases and for special reasons, grant exemptions from the provisions of the present Order provided that no obvious
danger to human life ensues.
Royal Order to issue Certain Regulations concerning Cinematograph
Theatres and Cinematograph Performances, dated 3 June 1932 1
CHAPTER I:

GENERAL PROVISIONS

1.
PU (1) For the purposes of the present Order, by "cinematograph
theatres" shall be understood premises employed for the public
performance of cinematograph pictures by means of highly inflammable films manufactured from nitrocellulose.
(2) If premises of the kind specified in subsection (1) are equipped
for purposes other than those mentioned therein, the necessary rooms
and equipment for such other purposes shall be exempt from the
provisions of the present Order in so far as they are not used for the
purposes of the cinematograph theatre.
(3) If performances of the kind referred to in subsection (1) take
place in tents or in connection with State-assisted instructional or
educational activities, and on these occasions only films intended for
such activities are used, then the provisions of Chapter II shall not
apply, even if the performance is public, but shall be replaced by the
relevant parts of the provisions of Chapter III.
(4) The performance of films in film laboratories or film offices
shall comply with the special regulations governing such performances.
2.
(Identical with section 2, subsection (1) of Order No. 178.)
CHAPTER I I : CINEMATOGRAPH THEATRES AND PUBLIC
CINEMATOGRAPH PERFORMANCES

A. — Permit for the Erection or Installation of Cinematograph Theatres
(Building Permit)
3.
(1) Any person desirous of erecting or installing a cinematograph
theatre in a locality in which there are no building inspection authorities or other authorities competent under the building regulations
in force to examine applications for building permits shall submit a
written application to the provincial Government.
(2) The local police authorities, and in localities where the Fire
Regulations apply the chief of the fire-brigade, shall express an opinion
on applications for permits to erect or install cinematograph theatres.
The factory inspector shall be notified of the application.
(3) The building permit shall contain the requirement that the
provisions hereinafter set forth under C and D concerning electrical
equipment and lighting equipment respectively shall be complied with.
(4) Cinematograph theatres shall not be used before they have
been approved by the authorities ¿ranting the building permit following
1

Svensk Författningssamling, No. 179 of 9 June 1932.
10

146

LEGISLATIVE MEASURES

upon an inspection ordered by such authorities. At this inspection
the local police authorities, and in localities in which the Fire Regulations apply the chief of the fire-brigade, shall be represented. If the
permit is granted by the provincial Government the owner of the
cinematograph theatre shall defray the cost of inspection to the amount
fixed by the said Government.
B. — Site and Construction
4.

Cinematograph theatres shall be so situated that the spectators
can easily reach a main thoroughfare of the width required for the
evacuation of the theatre, and that in case of fire the necessary fireextinguishing and rescue equipment can be brought to the theatre.
If the exit leads on to a courtyard the courtyard shall directly communicate with a public thoroughfare, and the clear width of the yard,
approach and gate shall be calculated according to the number of
persons having to use them in evacuating the theatre.
5.
In a building in which there is a cinematograph theatre there
shall be no inflammable equipment or stocks unless special precautions
are taken in consequence.
6.
Stairs, lift-shafts and ducts leading from the basement shall be
separated from the cinematograph theatre and ways out from it by
at least fire-resisting materials.
7.

(1) Except as otherwise provided in subsections (2), (3) and (4),
the parquet of the cinematograph theatre shall be on the ground
floor of the building.
(2) In buildings of which the outside walls, supporting structures,
intermediate ceilings and stairs are fireproof (fireproof buildings) the
parquet of the cinematograph theatre may be on a floor not higher
than the second, reckoned from the lowest ground level to which a
way out from the theatre leads.
(3) In buildings of which the outside walls and supporting structures are fireproof, the intermediate ceilings and partition walls fireresisting, and any wooden stairs faced underneath with at least fireresisting materials, the parquet of cinematograph theatres holding
not more than 600 persons may be on the first, and that of such
theatres holding not more than 300 persons on the second, floor.
(4) Cinematograph theatres holding more than 600 persons, or
galleries holding more than 150 persons, shall not be installed in buildings other than those mentioned in subsections (2) and (3). A cinematograph theatre holding not more than 300 persons may be installed
on the first floor if the ways out from the theatre, together with the
walls and the ceiling of the ground floor, are faced with fire-resisting
materials.
8.

Galleries shall be allowed in cinematograph theatres. In buildings
with fireproof outside walls and supporting structures, if the parquet

SWEDEN

147

lies on the ground floor, there may be three galleries, if on the first
floor two, and if on the second floor one. In other buildings there
shall be only one gallery, which shall not be higher than the first
floor.
9.
If the space between the floor joists and a sloping floor is used for
special purposes, at least the walls and the ceiling thereof shall be
faced with flame-obstructing materials.
10.
(1) From the parquet of a cinematograph theatre there shall be
at least two exits — main exit and emergency exit — leading directly
into the open or to ways out. The main exit may also serve as the
main entrance.
(2) Galleries holding more than 75 persons shall have at least
two exits: main exit and emergency exit. In the case of galleries
holding not more than 150 persons at least one of the stairways leading
to the exits, and in the case of galleries holding more than 150 persons
all stairways, shall be outside the auditorium.
(3) At the main exit, the parquet of a cinematograph theatre
shall not be more than 1.5 metres below the ground level to which
the way out from the said exit leads. At emergency exits the parquet
shall not be so low that in the way out from the exit, in addition to
a ramp with a slope not exceeding 1:10, more than twelve steps are
required.
11.
(1) The way out shall not communicate with rooms in which
there are inflammable appliances or stocks, or with ways out from
such rooms.
(2) The way out from an emergency exit shall not communicate
with the way out from a main exit unless special circumstances make
this necessary and appropriate precautions are taken.
12.
(1) The main exits and emergency exits from both the parquet
and the galleries of the cinematograph theatre shall be at opposite
ends of the parquet or gallery as the case may be. Nevertheless this
provision shall not apply to cinematograph theatres holding not more
than 600 persons and installed in fireproof buildings, or to cinematograph theatres holding not more than 300 persons and installed in
other buildings.
In cinematograph theatres in which the ceiling, walls and floor of
the operator's box, and the passages leading to it, are not fireproof,
at least one of the exits from the parquet shall be placed at the end
thereof opposite the box.
(2) The width of an exit shall not be less than 1.2 metres and
shall otherwise be so proportioned to the number of persons having
to use the exit that there shall be 1 metre clear between the doorposts
for every 150 persons in the case of main exits, and for every 300 persons in the case of emergency exits. If the parquet or the galleries
of a cinematograph theatre hold not more than 600 persons, the
exits may be so arranged that their aggregate width in the parquet
or in the gallery, as the case may be, is equivalent to 1 metre for every
150 persons.

148

LEGISLATIVE MEASURES

(3) The width of the ways out and of stairs leading down to them
shall be calculated in accordance with the provisions of subsection (2)
Cloakrooms or similar rooms shall not diminish the width of the
way out; nor shall there be any equipment in or by ways out that
might impede the evacuation of the premises.
(4) There shall be no steps within 0.75 metre of the exit from
a parquet or gallery.
13.
(1) In ways out, single steps shall not be allowed.
(2) The floor of ways out shall nowhere slope more than 1:10,
nor 1:20 in the outward direction if steps are built in the way out
beyond the falling stretch.
Slopes leading to steps shall terminate at a distance of at least
0.75 metre from the steps.
14.
In cinematograph theatres holding more than 300 persons, except
as otherwise provided in section 7, and except for vestibules, the
walls and the ceiling of ways out from the parquet shall be faced with
at least flame-obstructing materials; nevertheless, on such facing
wainscotting of wood or equivalent material may be laid to a height
of not more than 1.7 metres from the floor.
15.
(1) Stairs shall be provided on both sides with securely fastened
handrails without free ends.
Unless special circumstances necessitate otherwise, and the requisite precautions are taken in consequence, there shall be no landing
on stairs other than landings at which the direction of the stairs
changes.
There shall be no doors on stairs.
(2) The walls and ceilings of spaces enclosed under stairs shall
be provided with facing at least flame-obstructing.
Wooden stairs shall be provided underneath with facing at least
flame-obstructing.
(3) At a distance of 0.5 metre from the outer edge the steps shall
be not more than 0.4 nor less than 0.3 metre wide, and not more than
0.16 nor less than 0.14 metre high. There shall be no stairs with bends
unless at a distance of 0.25 metre from the inner edge the width of
the tread is at least 0.2 metre.
16.
(1) Doors in or leading to ways out shall be either tightly-closing
swing doors or other self-closing doors; they shall open outwards,
i.e. away from the theatre. Nevertheless, swing doors shall not be
placed in staircases, and doors opening outwards shall not be required
for compartments holding not more than ten persons (boxes). The
doors shall swing open through an angle of at least 90°; and shall
not be placed in such a position or such a manner that when open
they wholly or partly cut off the way out.
Exit gates of courtyards shall easily open outwards from the yard.
(2) The fastenings of the doors shall be easily openable by pressure
or a single manual operation. Nevertheless, on main exit doors, bolts
shall be allowed.

SWEDEN

149

17.
(1) In premises that are not equipped for purposes other than
those specified in section 1, subsection (1), cinematograph theatres
shall, apart from the boxes, be provided with fixed seating. As regards
the arrangement of the seats and gangways, the following provisions
shall be complied with:
(a) The seats shall be so arranged in rows in one or more blocks
with the necessary gangways as to allow of easy evacuation.
(b) When seats are installed on raised flooring of a height exceeding 0.5 metre, suitable railings shall be placed before the row
of seats nearest such flooring.
(c) When necessary the gallery parapet shall also be provided
with protective railings.
(d) Tip-up seats shall be so installed that when unoccupied they
automatically tip into the vertical.
(e) With tip-up seats there shall be a space of at least 0.8 metre
and with other seats a space of at least 1 metre between the rows.
(2) The width of the gangways mentioned in subsection (1) shall
in no case be less than 0.8 metre, and if they have to be used by 150 or
more persons, they shall be at least 1 metre wide for every 150 such
persons.
(3) For slopes up to 1: 10, gangways shall be in the form of ramps.
For steeper slopes, suitable stairs may be installed, but single steps
shall not be allowed. At the top of steps, gangways shall not rise
more than 1: 20. There shall be no steps within 0.75 metre of the exit
from the cinematograph theatre.
(4) There shall be no barriers intersecting the spaces between
the rows perpendicularly to the rows.
18.
(1) The operators' boxes, ways out from them, and ventilation
ducts in them shall be so installed that in case of a fire in the box
no smoke can penetrate into other parts of the building.
(2) The exits from operators' boxes shall only lead into the open,
either directly or through a special way out.
(3) Doors leading from operators' boxes shall be self-closing and
at least fire-resisting, and open outwards from the box.
19.
(1) The operator's box shall be of such dimensions that the airspace for each operator is at least 10 cubic metres; the floor space
shall be not less than 4 sq. metres and the height not less than 2
metres. There shall be unimpeded access to the way out from the
operator's box for each operator.
(2) To ensure proper ventilation, the operator's box shall be provided with both fresh-air and exhaust ducts. The exhaust duct shall
have a cross section of at least 300 sq. cm., and shall be so led into
the' open that there is no danger of a fire spreading. There shall be
no valves in the duct other than valves opening automatically in an
outbreak of fire.
(3) Walls of the operator's box abutting on the auditorium or
ways out from it shall be perforated only to the extent required for
the purposes of the projection, observation and stage-lighting ports;
other walls shall be perforated only for the purposes of the exit.

150

LEGISLATIVE MEASURES

The projection, observation and stage-lighting ports shall be closed
with glass at least 5 mm. thick, and shall not be made larger than
is absolutely necessary. The glass closing the said openings shall be
secured in the masonry or in smoke-tight metal frames.
Above the projection, observation and stage-lighting ports, iron
shutters shall be so fitted that in an outbreak of fire in the operator's
box the openings are automatically closed.
20.
(1) In cinematograph theatres holding more than 300 persons,
the ceilings, walls, floor and air ducts of the operator's box shall be
fireproof.
The way out from such operator's box shall be fireproof; nevertheless, it may be only fire-resisting if there is a room outside the box
that is lined with at least fire-resisting materials, and has doors that
are at least fire-resisting, close automatically, and open outwards from
the box.
The way out from the operator's box shall not communicate with
other rooms in the building.
(2) In cinematograph theatres installed for more than 150, but
not more than 300 persons, the ceiling, walls and way out from the
operator's box shall be faced with at least fire-resisting materials,
and ducts leading from the box shall be at least fire-resisting.
The way out from the operator's box shall have no communication
with the auditorium or ways out from it. In this connection, a fireresisting door locked by a cross bar inserted in strong fittings and
secured with a padlock shall not be deemed to be communication.
Further, the way out from the operator's box shall not communicate
with other rooms in the building unless outside the box there is a
room complying with the provisions of subsection (1), paragraph (2).
(3) In cinematograph theatres holding not more than 150 persons,
the ceiling and walls of the operator's box shall be faced with at least
flame-obstructing materials. The ducts leading from the box shall
not be made of unprotected wood. Unless they are fireproof, these
ducts shall not pass through the auditorium or ways out from it.
The way out from the operator's box shall have no communication with the auditorium or ways out from it. In this connection,
strong windowless doors kept locked in the manner specified in subsection (2) shall not be deemed to be communication.
21.
If difficulties in the lay-out of the building would otherwise arise,
in cinematograph theatres installed in educational establishments,
the way out from the operator's box may communicate with the way
out from the auditorium subject to compliance with the following
provisions:
(a) If there is a gallery, the floor of the operator's box shall not
be lower than the floor of the gallery.
(ft) Outside the operator's box shall be constructed a room lined
with at least flame-obstructing materials, and having doors that are
fire-resisting, close automatically and open outwards from the box.
Further, the said room shall be provided with a smoke duct with a
cross section of at least 300 sq. cm. and so led into the open that there
is no danger of a fire spreading.

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151

(c) The exit from the room referred to in (b) shall lead to another
room, separated from the way out from the auditorium by at least
fire-resisting walls and a fire-resisting door that closes automatically
and opens inwards, i.e. towards the operator's box.
C. — Electrical Equipment
22.
(1) Heavy-current electrical equipment for lighting, heating
or power transmission shall be so constructed and installed that lamps,
motors, heating and other consuming appliances together with their
accessories and wiring shall entail no danger of ignition. As far as
possible such equipment shall be fixed in position.
(2) Fixed electric wiring in the operator's box shall be placed so
far from the projector, or so screened off from it, or as regards live parts,
so protected that the film cannot be ignited by it.
(3) Apart from the provisions of subsections (1) and (2), existing
or future general regulations for the construction of electrical equipment
shall be complied with.
D. — Lighting

Equipment

23.
(1) Cinematograph theatres and ways out from them shall be provided with both general and emergency lighting.
(2) Courtyards to which exits lead shall also be lighted.
(3) If the general lighting is electric it shall be possible to switch
on the lighting required for the evacuation of the cinematograph
theatre both from the operator's stand in his box and from a vestibule
in the theatre.
(4) For lighting the operator's box and ways out from it electric
filament lamps shall be used.
24.
(1) Emergency lighting shall be provided above or by every exit
leading directly into the open or to a way out.
If the emergency lighting mentioned in subsection (1) does not
suffice for the evacuation of the cinematograph theatre, there shall
be in the auditorium and ways out from it additional emergency
lighting of such intensity as to ensure independently adequate illumination for the purpose in question. Stairs in the auditorium shall be
provided with emergency lighting.
(2) The emergency lighting system shall be so installed that it
cannot be put out of action by a fire in the operator's box. It shall
be completely independent of the main lighting. If electric emergency
lighting is installed, and no special circumstances necessitate a different
arrangement, the emergency and main lighting systems may be connected to the same feeder provided that the connection is effected
by main wiring separated inside the building.
When there are more than four electric lamps in the emergency
lighting system, they shall be so connected in groups that adjoining
lamps are not wired to the same group fusegear. Nevertheless, this
provision shall not apply to the stair lighting mentioned in subsection
(1), paragraph (2).

152

LEGISLATIVE

MEASURES

E. — Projectors
25.
(1) Projectors shall be provided with drums (brandkassetter) the
mouthpieces of which have double pairs of rollers (extinguishing
rollers) or other suitable safety devices, together with fastenings such
that they cannot be inadvertently opened. During the performance
the drums shall be kept closed.
While the projector is not working the heat and light rays passing
through the lenses shall be caught by two incombustible screens, one
self-acting and the other worked by hand.
The illuminant for the projector shall be electricity.
(2) Without prejudice to the provisions of subsection (1) projectors
other than those specified therein may be used if approved as to
construction by the Government Material Testing Institute; similarly,
in the projectors other illuminants than electricity may be used if
their installation is approved by the said Institute.
26.
(1) In any circumstances other than those mentioned in subsection (2), projectors shall be installed in special operator's boxes.
(2) If use is made of projectors in which the film can remain
stationary for a certain time without being ignited (school apparatus)
and if such projectors are of a type approved by the Government
Material Testing Institute after being tested as to fireproofness, they
may be installed either:
in a room adjoining the auditorium and so situated that in case
of fire the way out from the building is not cut off; or
in the auditorium itself, as far as possible from the places and gangways provided for the spectators, and from doors leading to
the way out.
Projectors shall not be less than 5 metres from fireplaces in use.
Around the projector shall be a space measuring at least 1 metre in
all directions and suitably separated off, to which only the operator
and the occupier of the premises or his representative shall have access.
27.
Projectors other than school apparatus as defined in section 26,
subsection (2), shall only be operated by persons in possession of a
valid operator's licence.
Applications for operator's licences shall be submitted to the
police authorities of the locality in which the applicant is domiciled;
they shall mention the applicant's full name, occupation, and place
of residence.
Applications shall be accompanied by:
(a) a certificate showing the applicant's age;
(b) a certificate from the person authorised by the police authorities to undertake the necessary tests, stating that in so far
as safety is concerned, the applicant is fully conversant with
the operation of the projector and possesses the necessary
knowledge of the working regulations in force for cinematograph performances.
If the applicant has properly furnished the information required
above, is eighteen years old, and not to be considered unsuitable on any

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153

grounds for the operation of the type of projector in question, the police
authorities shall issue an operator's licence.
The said licence shall be valid in localities other than the locality
of issue, but may be revoked when there are reasons therefor by the
issuing authorities.
(2) School apparatus shall be operated only by persons fully
conversant with it.
F. — Working Regulations
28,
(1) Every cinematograph theatre shall have a manager, who may
be either the occupier or a person selected by him; if necessary, there
shall be a substitute for t h e . manager. Only persons twenty-one
years old and of good repute may be managers or their substitutes.
(2) It shall be for the occupier of the cinematograph theatre to
notify the police authorities of the name of the manager, and if a
substitute is appointed, that of his substitutes, together with their
addresses.
If the police authorities consider that the manager or his substitute
is unsuitable for their respective posts, the occupier shall appoint
another person when so requested by the said authorities.
29.
Above or by every exit leading directly into the open or to a way
out, and if necessary over doors in the way out, the word " E x i t "
shall be clearly and suitably displayed. The same indication shall be
displayed near the emergency lighting in ways out.
30.
(1) Ways out shall not have hangings or curtains in them, and
shall not be otherwise so obstructed by appliances or other objects
that evacuation is impeded.
(2) When there are door bolts these shall remain open so long
as the cinematograph theatre is occupied by the public.
31.
(1) Seats shall not be installed in the gangways of the auditorium.
Standing accommodation shall not be sold.
(2) Any temporary installation of benches or chairs shall comply
with the provisions of section 17, subsections (1) (a) and (2), together
with any special regulations issued by the local police authorities as
to ranging benches or chairs or fastening them to the floor. In localities in which the Fire Regulations apply, the chief of the fire-brigade
shall also express his opinion on the installation.
32.
(1) Spirits or inflammable oils in Danger Class I shall not be used
for lighting purposes.
For emergency lighting only electric filament lamps, stearinecandle lanterns or colza-oil lamps shall be allowed.
(2) The emergency lighting shall remain on so long as any spectators remain in the cinematograph theatre or ways out from it. Above

154

LEGISLATIVE

MEASURES

or by the exits specified in section 24, subsection (1) (a), shall be placed
either a red lamp forming part of the emergency lighting, or a board
illuminated by the emergency lighting and displaying the word
" Exit " suitably and clearly.
(3) Without the special permission of the local police authorities
temporary lighting shall not be installed in cinematograph theatres;
or stuffs, paper or other highly inflammable materials be placed near
the light fittings or electric equipment of such theatres. In localities
in which the Fire Regulations apply, the chief of the fire-brigade shall
be .consulted before permission is granted.
(4) Movable wiring of electric lighting equipment shall be in the
form of cab-tyre conductors, and shall not be longer than is absolutely
necessary. Hand lamps in operator's boxes shall be provided with
protective globes and wire guards. If lamps with counterweight fittings
are used as hand lamps, they shall be provided with hand-lamp fittings.
33.
(1) In the cases mentioned in section 21, or section 26, subsection
(2), there shall not be more than 15 kg. of film in a cinematograph
theatre; and in the cases mentioned in section 20, subsection (3), not
more than the quantity required for one performance; and in other
cases not more than 45 kg.
Apart from the cases mentioned in section 26, subsection (2), the
film shall be kept in the operator's box. Films not in the projector nor
on the winding mechanism shall be placed in a cupboard of oak or
other material affording equivalent security against fire. The cupboard
shall have a separate compartment, with a tightly closing and selffastening lid, for each film reel.
(2) Radiators and heating elements, together with the pipes leading
to them, shall be so protected that films cannot be laid on or near them.
34.
In the case of film performances with school apparatus as defined
in section 26, subsection (2), apart from the other provisions of the
present Order the following provisions shall be specially complied with :
(a) In the auditorium there shall be no films except that in the
projector, and all other films shall be stored in a room separated from
the auditorium and the way out from it.
(b) Films shall not be wound in the auditorium before the spectators
have left it.
(c) Electric series resistances shall be so placed that they cannot
ignite the film or other inflammable materials.
(d) Other measures shall be taken to prevent films approaching the
electrical equipment of the projector, or any other objects capable of
igniting them.
(e) Smoking and the use of matches or fire in any other form shall
be prohibited in the auditorium, or, if the projector is in a room as
defined in section 26, subsection (2), in that room. Notices to this effect
shall be placed at suitable places in the auditorium and in the said
projector room.
(/) In the immediate vicinity of the projector there shall be at least
a bucket-pump or pail of adequate size kept full of water, or a chemical
fire extinguisher of a type approved for this purpose by the Government Material Testing Institute.

155

SWEDEN

35.
(1) In operator's boxes and ways out from them smoking and the
use of matches or fire in any other form shall be prohibited. Notices
to this effect shall be conspicuously affixed at suitable places in or by
the box.
(2) At suitable places in or by the operator's box there shall be a
suitable number of bucket-pumps or pails kept full of water, or chemical
fire extinguishers of a type approved for this purpose by the Government Material Testing Institute. These places shall be indicated by the
words "Fire extinguisher ".
(.J) In localities where there is a fire-brigade, a t a suitable place
in or by the operator's box, shall be affixed a notice indicating the
nearest fire alarm or other means of summoning the fire-brigade.
CHAPTER I I I :

NON-PUBLIC CINEMATOGRAPH

PERFORMANCES

36.
(1) Premises that are not approved as cinematograph theatres shall
not be made available or used for non-public cinematograph performances with films as defined in section 1 unless they are approved for
this purpose by the local police authorities.
(2) Such approval shall only be granted if the premises are found to
comply with the provisions of the present Chapter after an inspection
ordered by the local police authorities. In localities in which the Fire
Regulations apply, the chief of the fire-brigade shall be represented at
such inspections.
If the premises are approved, the police authorities shall issue
regulations dealing with the following points in particular :
(a) The place for installing the projector.
(b) The arrangement of the seating which with due regard to the
existing installation shall be governed by the provisions of section 17,
subsections (1) (a) and (2).
(c) The keeping open during the performance of sliding doors in or
leading to ways out from the premises; during the performance such
doors shall be so fixed open that they cannot be closed.
(3) Premises in educational establishments may be approved for
indefinite periods, and other premises for not more than one year.
The person to whom a permit is made out shall be responsible for
observance of the regulations governing the performances.
(4) The provisions of the present Chapter shall not apply to film
performances in private houses.
37.
Premises of the kind dealt with in section 36, subsection (1), shall
not be so situated in the building that in case of fire means of escape
the for persons in the other parts of the building are impeded.
The premises shall have at least two exits; in schools, classrooms
with only one exit may be used for cinematograph performances if the
projector is a school apparatus as defined in section 26, subsection (2).
38.
(1) Projectors shall comply with the provisions of section 25 or
section 26, subsection (2). Drums shall be kept closed during the
performance.

156

LEGISLATIVE

MEASURES

(2) In cases other than those dealt with in section 39, the projectors
shall be installed as required by the provisions of section 26, subsection (2), for school apparatus. The provisions of the said subsection
respecting the space to be separated off shall be complied with.
The following provisions shall be also complied with:
(a) At performances under this Chapter there shall not be more
than 15 kg. of film, and only the film in the projector shall be in the
auditorium, the remainder being kept in a room separated from the
auditorium and ways out from it.
(b) Films shall not be wound in the auditorium until the spectators
have left it.
(c) Electric series resistances shall be so placed that they cannot
ignite the film or other combustible materials.
(d) The operator shall not leave the space separated off until the
projector has stopped working.
(e) Within the space separated off, smoking and the use of matches .
or fire in any other form shall be prohibited.
(J) In the immediate vicinity of the projector there shall be at least
a bucket-pump or pail of suitable size, and kept full of water, or a
chemical fire extinguisher of a type approved for such purposes by the
Government Material Testing Institute.
(3) As regards authorisation to act as operator, the provisions of
section 27 shall apply, mutatis mutandis.
39.
If for cinematograph performances in educational establishments
use is made of projectors other than school apparatus as defined in
section 26, subsection (2), they shall be installed in operator's boxes.
To these boxes and ways out from them the provisions of sections 18 to
21 shall apply, mutatis mutandis.
CHAPTER IV:

PENAL PROVISIONS, ETC.

40.
(1) Anyone who grants the use of, or uses for cinematograph performances, premises not authorised for this purpose by the competent
authorities, or anyone who without an official permit makes alterations
in approved premises such as might be prejudicial to their use for
cinematograph performances, and subsequently uses or grants the use
of such premises for such performances, shall be liable to a fine of not
less than five days' income.
(2) For offences against the provisions of sections 22 to 24 in
respect of such equipment or installations mentioned therein as are not
to be considered as parts of the building, the occupier of the cinematograph theatre shall be liable to a fine of not less than five days' income.
41. .
(1) If use is made of projectors not complying with the provisions
of section 25 or 26, subsection (2), or if the provisions of section 26
concerning installation of the projector, or those of section 27 concerning
authorisation to act as operator, are infringed, the occupier of the
cinematograph theatre or the person responsible for the performance
under section 36, subsection (3), shall be liable to a fine of from 5 to
300 kronor.

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157

(2) Anyone shall be liable to a like penalty who infringes the provisions of sections 28 to 35, or special regulations issued under these
provisions by the competent authorities, or the provisions of section 38
or 39, or regulations issued under section 36 by the competent authorities.
42.
(Identical with section 30 of Order No. 178.)
43.
(Identical with section 31 of Order No. 178.)
44.
(Identical with section 32 of Order No. 178.)
(1) The present Order shall come into force on 1 January 1933
except as hereinafter provided in Regulations Nos. 2 to 10.
(2) The provisions of sections 5, 25, 26, subsection (1), 27 and 38,
subsections (1) and (3), shall not be operative until one year, and the
provisions of section 39 until two years, after the entry into force of the
present Order.
(3) The provisions of section 4 shall not apply to cinematograph
theatres in existence at the entry into force of the present Order, and
the provisions of sections 6 to 24 shall apply only if not otherwise
provided in Regulations 4 to 8 hereinafter.
(4) After the entry into force of the present Order, owners of existing
cinematograph theatres (Regulation 3) who are desirous of continuing
to use or to grant the use of the said theatres for cinematograph performances, shall notify the same in writing within not more than three
months of the entry into force of the present Order. In localities in
which there are building inspection authorities or other authorities
competent to examine building applications, the notification shall be
submitted to such authorities ; and in other localities to the provincial
Government.
(5) If a notification as specified in Regulation 4 is received by any
of the authorities mentioned therein, the said authority shall order an
inspection of the cinematograph theatre. The owner or his representative shall be afforded an opportunity of taking part in the inspection.
Further, the local police authorities, and in localities in which the Fire
Regulations apply, the chief of the fire-brigade, shall be represented
even if such authorities have not been ordered to carry out the
inspection.
(6) If in the course of an inspection held under Regulation 5, the
cinematograph theatre is found to comply fully with the provisions
of the present Order, it shall be approved for cinematograph performances by the authority to which the notification was submitted.
(7) If in the course of the said inspection it is found that the cinematograph theatre does not fully comply with the provisions of the
present Order, proposals shall be submitted to the authorities mentioned
in Regulation 4 for removing the defects so found. In the examination
of such proposals the following provisions shall be complied with :

158

LEGISLATIVE

MEASURES

(a) The ducts mentioned in section 6 may be installed as iron
piping with protective covering.
(f>) To the provisions of sections 7, 8, 10, 11, subsection (2), 12,
subsections (1), (2) and (3), paragraph (1), and 13, subsection (2), such
exceptions may be allowed as seem justified in each individual case
and entail no obvious danger to human life, provided that in the case
of exceptions to the provisions of section 10, subsection (2), there shall
be not less than two exits from galleries holding more than 150 persons,
and in the case of exits as specified in section 12, subsection (2), no
width less than 1.2 metres shall be allowed.
(c) Exceptions may be allowed to the provisions of section 14 in
respect of main exits and the cloakrooms and vestibules in connection
therewith, if the emergency exits are large enough and lead into the
open either directly or through a vestibule only, and the conditions
are otherwise favourable.
(d) Such exceptions may be allowed to the provisions of section 15,
subsection (1), paragraph (2), and subsection (3) as seem justified in
each individual case, and entail no obvious danger to human life.
Similarly, for stairs that have to be used by not more than seventyfive persons, a flame-obstructing facing, as specified in section 15,
subsection (2), may be dispensed with.
(e) Such exceptions may be allowed to the provisions of section 16,
subsection (2), concerning prohibition of door bolts, section 17, subsections (1) (e), (2) and (3), and section 19, subsection (1), as may seem
justified in each individual case, and entail no obvious danger to human
life, provided that for gangways as specified in section 17, subsection (1),
no width less than 0.8 metre shall be allowed, and provided also that no
single steps are allowed.
(/) For cinematograph theatres holding not more than 450 persons,
the provisions of section 20, subsection (1), paragraphs (1) and (2) may,
by way of exception, remain inoperative in so far that the ceiling, walls
and floors of the operator's box may be fire-resisting and its substructure
need not be fireproof, if it nevertheless possesses adequate bearing
strength and is fire-resisting.
(g) If in cinematograph theatres holding not more than 450 persons
the installation of a separate way out from the operator's box raises
special difficulties, the provisions of section 20, subsection (1), paragraph (3), may remain inoperative in so far that the way out from the
operator's box may lead to a way out from the auditorium or to
another room in the building, in which case the provisions of section 21,
paragraphs (6) and (c) shall apply.
(ft) The way out from an operator's box as specified in section 20,
subsection (2), may lead to a way out from the auditorium or to
another room in the building, in which case the provisions of section 21,
paragraphs (Z>) and (c) shall apply.
(i) Ways out, as specified in section 20, subsection (3), paragraph (2),
may lead to a way out from the auditorium, in which case the provisions
of section 21, paragraphs (b) and (c) shall apply.
(/) In cinematograph theatres, as specified in section 20, ducts
leading from the operator's box may be installed in compliance with
the provision in (a) for ducts leading from basements, provided that
they are nowhere less than 25 cm. from wooden parts.

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159

(8) In the decisions to be communicated under Regulation 7,
paragraph 1, the authorities shall fix a time-limit for the removal of the
defects referred to therein, after the expiry of which the cinematograph
theatre shall not be used or made available as such. In the case of
operator's boxes and ways out from them, the time-limit shall expire
not later than two years, and in other cases, if considerable work is
involved, not sooner than three years after the entry into force of the
present Order. When the work is ended, the cinematograph theatre
shall be inspected as soon as possible. For this inspection and for
authorisation of the opening of the theatre, the provisions of section 3,
subsection (4) shall apply, mutatis mutandis.
(9) If in the course of an inspection under Regulation 5, the
cinematograph theatre is found to be in such a condition that the
cinematograph performances taking place therein may entail obvious
danger to human life, the provincial Government shall prohibit the
use of the theatre, or certain parts thereof, until the necessary measures
have been taken. If the inspection is ordered by the building inspection
authorities or authorities corresponding to them, and if the premises
are found in the said condition, the said authorities shall immediately
notify the provincial Government.
(10) Regulations 4 to 9 shall also apply, mutatis mutandis, to cinematograph theatres which, at the entry into force of the present Order,
are under construction or undergoing equipment, as well as to those
the construction of which is begun subsequent to the said entry into
force under a building permit issued prior thereto.

SWITZERLAND
There is no special legislation for the celluloid industry, but
under section 80 of the Factory Act of 3 October, 1919, Administrative Regulations have been issued requiring the "workrooms
to be fireproof and also containing provisions concerning exits,
the width of passage-ways and dust removal. The industry is
also covered by the regulations for.the working of highly inflammable or explosive substances, which lay down that the workshops concerned shall not lie under inhabited premises or
premises constantly occupied by persons; and that the stairs,
heating and lighting shall comply with specific requirements.
There are also regulations for the storage and removal of
waste.

OTHER COUNTRIES
In Hungary there are regulations dated 28 June 1923,
concerning the manufacture, working and storage of celluloid.
In Czechoslovakia regulations have been in existence since
March 1925 for the manipulation of celluloid, the manufacture
of celluloid goods, and the treatment of scrap.
The employment of women in celluloid working is said to be
forbidden by law in Argentina, and that of all juveniles under
eighteen years of age in Greece.

BIBLIOGRAPHY

Scientific Handbooks, Annual Reports, etc.
S Y R U P , D r . F . Handbuch des Arbeiterschutzes
und der Betriebssicherheit. 3 vols. Berlin, Verlag Reimar Hobbing, 1927.
E R D M A N N - K Ö N I G : Warenkunde.
2 vols. Leipzig, Verlag J . A .
Barth.
BLÜCHER, H . Auskunftsbuch
für die Chemische Industrie.
Berlin,
Verlag Walter de Gruyter & Co.
OST. Chemische Technologie. Leipzig, Verlag M. Jaenecke.
LEHMANN, K. B . Lehrbuch der Arbeits- und Gewerbehygiene. Leipzig,
Verlag Hirzel.
INTERNATIONAL LABOUR O F F I C E . Encyclopaedia

of Industrial

Hygiene.

Vol. I. Geneva.
Annual Reports of t h e Factory Inspectorates of various countries:
Austria, Germany, Great Britain, Netherlands, Switzerland.
Jahresberichte der Gewerblichen Berufsgenossenschaften
über Unfallverhütung. Berlin, Verlag Reimar Hobbing.
Jahresberichte der Chemisch-Technischen Reichsanstalt, Berlin, 19241925, 1928.
Periodicals
The undermentioned periodicals contain articles on t h e manufacture
and manipulation of celluloid:
Kunststoffe,
Zeitschrift für Erzeugung und Verwendung
veredelter
oder chemisch hergestellter Stoffe. Munich, Verlag J . Lehmann.
Reichsarbeitsblatt.
Published by t h e Federal Ministry of Labour,
Berlin.
Zentralblatt für Gewerbehygiene und Unfallverhütung.
Berlin, Verlag
Springer.
INTERNATIONAL LABOUR O F F I C E . Industrial

Safety Survey.

Geneva.

National Safety News. Chicago.
Chemikerzeitung.
Cöthen i. Anh., Verlag Otto v . Halem.
Vierteljahrsschrift für gerichtliche
Medizin.
Münchener Medizinische Wochenschrift, 1929:
(a) Report on t h e Dangers of Poisoning by X - R a y Films (Cleveland),
No. 25, p . 1049.
(b) Reply of J . G. Farben A. G. t o t h e above in No. 37, p . 1565.