Warehousemen's Liens Act Regulations and Rules of Court 1952

The regulations revolve around a small set of practical concepts tied to notices, proof and documentary particulars.

• Notice of claim (Form 1, regulation 3 and Schedule 1 Form 1). A person asserting ownership of goods deposited with a warehouseman, or an interest in those goods, must give notice in the form prescribed. The Form 1 template requires the claimant’s full name, particulars of the goods, the identity of the depositor and an address authorised for service of Act-required notices.

• Notice of lien (Form 2, regulation 4 and Schedule 1 Form 2). A warehouseman who wishes to give notice of lien must do so using the Form 2 template. Regulation 4 sets a deadline for that notice: it must be given within three months after the date of deposit of the goods.

• Notice by advertisement (regulation 5). Where the person entitled to receive notice under the Act is unknown to the warehouseman, or no address is known, the regulations permit service by advertisement. The advertisement must include a full copy of the notice and be published at least twice with an interval between publications of at least seven days. Publication must be in a newspaper circulating in the locality of the warehouseman’s premises; where that newspaper is not a daily, an advertisement must also be published in a daily newspaper circulating in the City of Perth. The regulations establish that notice by advertisement is deemed given on the day the last required advertisement appears.

• Statement of account verification and required particulars (regulation 6). Duplicate copies of the statement of account that the warehouseman must furnish (pursuant to section 10(4) of the Act as referenced) must be verified by statutory declaration made by the warehouseman or a competent person. When paying any surplus into a Magistrates Court or to the Treasurer, the warehouseman must furnish in writing specified particulars: date of deposit; names and addresses of depositor, owner and every claimant and the grantee under any bill of sale of which the warehouseman has notice; particulars of all claims known to the warehouseman; particulars and results of searches made under the Bills of Sale Act 1899; and any other information relating to the transaction known to the warehouseman (regulation 6(2)(a)-(e)).

• Offence and penalty (regulation 7). Contravention of any provision of these regulations is an offence, carrying a fine of $20 (regulation 7).

The Schedule supplies the exact wording for Form 1 (Notice of Claim) and Form 2 (Notice of Lien), including the particulars to be included in the schedule to each form. Form 2 includes a table for repeating entries describing goods, warehouse location, date of deposit and depositor. The regulations therefore translate the Act’s broad notice and accounting obligations into concrete templates and timing rules.

The regulations allocate roles, duties and informational obligations among a defined set of actors.

• Warehousemen. Primary obligations fall on warehousemen. They must give notices of lien within the specified time frame (regulation 4), use the prescribed Form 2 when giving notice (regulation 4 and Schedule 1 Form 2), verify duplicate statements of account by statutory declaration (regulation 6(1)), and provide specified written particulars when paying surplus amounts into a Magistrates Court or to the Treasurer (regulation 6(2)). The warehouseman is also the person who decides if an addressee is unknown and therefore whether to use the advertisement route (regulation 5(1)).

• Claimants / owners / depositors. Persons asserting ownership or an interest in goods deposited with a warehouseman must lodge a notice in the prescribed Form 1 (regulation 3 and Schedule 1 Form 1). Form 1 requires the claimant to supply particulars of the goods and to nominate an address for service of notices under the Act. The depositor is a named actor in Form 2 and in the particulars required by regulation 6(2)(b).

• Persons claiming an interest and grantees under bills of sale. Regulation 6(2)(b) expressly extends the particulars the warehouseman must supply to include every person claiming to be the owner or having any interest, including the name and address of the grantee of the goods under any bill of sale of which the warehouseman has notice.

• Unknown persons and the public. Where a person to be notified is unknown or their address is unknown, the regulations permit the warehouseman to give notice by advertisement (regulation 5). That process involves public newspapers , a local newspaper circulating where the warehouseman’s premises are situated, and potentially a daily newspaper in the City of Perth if the local paper is not daily (regulation 5(2)).

• The Magistrates Court and the Treasurer. Regulation 6(2) allocates a role to the Magistrates Court and the Treasurer: at the time the warehouseman pays any surplus into either body, the warehouseman must also furnish the specified written particulars to that body. The regulations therefore impose an information-delivery duty to these institutional recipients.

• Newspapers (publishers) and services of publication. The regulations implicitly engage newspaper publishers and require two publications separated by at least seven days if service by advertisement is used (regulation 5(2)).

These regulations therefore impose recordkeeping, verification and publication duties primarily on warehousemen and impose a standard form and address-authorisation duty on claimants. They require interaction between warehousemen and the Magistrates Court or Treasurer when funds are paid over.

The regulations create a short list of express duties and corresponding procedural rights.

Duties imposed on the warehouseman

• Use prescribed forms: A warehouseman must accept and act on notices in the prescribed forms. Regulation 4 requires that the notice of lien given within three months after deposit must be in the form set out at Schedule 1 Form 2. Regulation 3 requires that any claim of ownership or interest by a person must be in accordance with Schedule 1 Form 1.

• Timing of notice of lien: Regulation 4 fixes a deadline: the notice of lien must be given within three months after the date of deposit of the goods. That is an externally imposed timing duty the warehouseman must observe to satisfy the regulation’s wording.

• Advertisement where addressee unknown: Regulation 5 requires the warehouseman, in cases where an intended notice recipient is unknown or there is no known address, to give notice by advertisement, comply with publication frequency and venue requirements, and accept the deemed date of service on the day of the last publication (regulation 5(3)).

• Verification of statements: Regulation 6(1) requires duplicate copies of the statement of account (referenced to section 10(4) of the Act) to be verified by statutory declaration made by the warehouseman or a competent person on the warehouseman’s behalf. The duty is to verify the duplicates.

• Furnish particulars when paying surplus: Regulation 6(2) imposes a duty to furnish in writing specified particulars at the time of paying the surplus into a Magistrates Court or to the Treasurer. These particulars are detailed and include deposit date, names and addresses of the depositor and owner and every claimant and grantee under any bill of sale of which the warehouseman has notice, particulars of all claims known to the warehouseman, particulars and results of searches under the Bills of Sale Act 1899, and other relevant information known to the warehouseman.

• Maintain records supporting searches and claims: While not expressed as a standalone duty, the requirement to provide particulars and search results (regulation 6(2)(c)-(d)) creates a practical obligation to undertake and retain records of searches and known claims.

Rights or procedural entitlements

• Right to serve by advertisement: Regulation 5 grants the warehouseman the procedural right to serve notice by advertisement where an addressee or address is unknown, subject to the publication requirements set out.

• Right to use statutory-declaration verification: Regulation 6(1) permits the warehouseman to have duplicates of the statement of account verified either by the warehouseman or by a competent person on the warehouseman’s behalf, which provides a degree of operational flexibility.

• The notice forms confer limited rights on claimants: Form 1 in Schedule 1 gives the claimant the right to authorise the warehouseman to serve all notices required by the Act at a nominated address. That creates an expectation that notices will be sent to the nominated address.

Enforcement backstop

• Breach is an offence: Regulation 7 converts contravention of any provision of these regulations into an offence with a monetary penalty of $20. This is the statutory enforcement mechanism expressly contained in the regulations.

Scope and limits

• Procedural not substantive: The regulations specify forms, timelines and documentary steps; they do not, within their own text, define the substantive scope of a warehouseman’s lien rights, the circumstances in which sale may take place, or the rights of claimants beyond the service and particulars mechanics. Those substantive matters are matters for the Act; the regulations implement procedural mechanics relating to notices, advertising, verification and particulars.

The regulations provide a single, explicit criminal sanction for non-compliance. Regulation 7 states: "A person who contravenes a provision of these regulations commits an offence. Penalty: a fine of $20." That is the sole enforcement provision contained in the regulations.

Implications of the penalty design

• Monetary quantum: The prescribed penalty is a fixed monetary fine of $20. The regulations do not include any escalating fines, imprisonment, or other punitive sanctions. The text does not specify whether the penalty amount is current-dollar or has been indexed; the reprint notes show the regulations were compiled as at 2 November 2007 and that regulation 7 was inserted by Gazette 24 Aug 2007, but the regulations do not provide further adjustment mechanisms within the text.

• Breadth of offence: The offence is framed broadly,any contravention of a provision of these regulations attracts the penalty. That means failure to use the prescribed forms, failure to give a notice within the three-month period, failing to publish the advertisement twice with the required interval and venue, failing to verify duplicate statements by statutory declaration, or failing to furnish the particulars required when paying surplus could all be treated as contraventions subject to the penalty.

• Enforcement mechanism unspecified: The regulations do not specify which enforcement or prosecuting authority administers or prosecutes the offence, nor the procedure for prosecution, nor which court hears the matter. The text confines itself to declaring the contravention an offence and fixing the fine.

• Administrative avenues: The regulations require certain administrative acts (for example, furnishing particulars to the Magistrates Court or Treasurer when paying surplus per regulation 6(2)). Those administrative acts are separate from the criminal sanction. The regulations do not specify statutory remedies for claimants in the event of non-compliance with the notice or verification rules; any such remedies would be found in the Act or other law.

Practical enforcement considerations

• Deterrence and compliance incentives: The relatively small fixed penalty suggests the regulations operate primarily as procedural hygiene rules rather than as a vehicle for significant punitive enforcement. The presence of the penalty does, however, create a legal backstop that makes compliance a legal obligation and permits criminal sanction for deliberate or negligent contravention subject to prosecutorial discretion and court processes not specified in the regulations.

• Proof and recordkeeping: Because contraventions are penally actionable, the supporting documentary steps required by these regulations (verified duplicate statements, proofs of publication, particulars supplied to courts or the Treasurer) will be central to establishing compliance or non-compliance in any enforcement action.

The regulations reference and function as procedural adjuncts to other legislation, and they require interaction with specified statutory actors.

• Relationship with the Warehousemen’s Liens Act 1952. The regulations are framed as subordinate to, and operative under, the Act. They implement sections of the Act by prescribing forms and procedures for notices referenced to particular Act sections: regulation 3 and Schedule 1 Form 1 operate pursuant to "section 6(1)(a)"; regulation 4 (notice of lien) operates pursuant to "section 6(2)"; regulation 5 addresses the advertisement mode under "section 9(3)"; regulation 6 implements the procedural mechanics tied to "section 10(4)" of the Act. The regulations do not reproduce or alter the substantive provisions of the Act; they supply prescribed forms and procedural steps for carrying out the Act’s notice and accounting requirements.

• Connection to the Bills of Sale Act 1899. Regulation 6(2)(d) requires the warehouseman to provide particulars of "all searches made by or on behalf of the warehouseman under the Bills of Sale Act 1899 and of the results of such searches." The regulation therefore creates an expectation that the warehouseman will conduct searches under that Act and record the results for disclosure when paying surplus. The regulations do not detail the scope or procedure of such searches; they merely impose a disclosure requirement in respect of any searches the warehouseman has made.

• Interaction with Magistrates Court and Treasurer processes. Regulation 6(2) requires the warehouseman, at the time of paying the surplus, to furnish specified particulars in writing to the Magistrates Court or the Treasurer as the case may be. The regulations thus engage existing institutional payment processes operated by courts or a treasury agency; they require information flows to those bodies but do not specify how the Magistrates Court or Treasurer should process or act on that information.

• Statutory declaration regimes. Regulation 6(1) requires verification of duplicate statements of account by statutory declaration. That links the regulations to the statutory frameworks governing statutory declarations, including who qualifies to make them and the legal effect of a statutory declaration. The regulations do not set those rules themselves; they require compliance with the declaration mechanism.

• Publication and media law. Regulation 5 prescribes use of newspapers for service by advertisement and defines when notice by advertisement is deemed given. That engages commercial newspapers and the mechanics of publication. The regulations do not address other modes of public notice such as electronic publication.

• No conflict clauses visible. The text of the regulations does not include express conflict-of-laws clauses; it is silent on how to resolve inconsistencies with any other subordinate instruments. The regulations are to be read as implementing the Act for the specific procedural items they address.

Overall, the regulations are narrowly aimed at harmonising procedural practice with the Act and ensuring certain documentary and publication standards; their interaction with other laws is primarily through prescribed cross-references to the Act, reliance on statutory-declaration frameworks, the Bills of Sale Act 1899 in relation to searches, and the institutional roles of the Magistrates Court and Treasurer.

The reprint notes and compilation table in the provided text record the regulations’ publication and amendment timeline as compiled to 2 November 2007.

Chronology from the document

• Original instrument. The instrument began as the Warehousemen’s Liens Act Regulations and Rules of Court 1952, gazetted 20 February 1953 (20 Feb 1953 p. 368‑71), with that gazettal date recorded as the commencement date in the compilation table.

• Decimal currency change. A reference is made to the Decimal Currency Act 1965 (assented 21 December 1965). The compilation table notes timing for parts of that Act but does not show a specific separate amending instrument for the Regulations beyond indicating an amendment for currency purposes. It records that the Decimal Currency Act affected parts of the Regulations in December 1965 and February 1966; the details are recorded parenthetically but the Regulations themselves do not explain amendment content within the reproduced text.

• 2007 amendments. The Warehousemen’s Liens Amendment Regulations 2007 were gazetted on 24 August 2007 (Gazette 24 Aug 2007 p. 4319‑21). The 2007 amendments effected multiple textual changes noted in the reprint: regulation 1 was amended (see r. 1 amended note), regulation 2 was deleted, several headings were deleted, regulation 7 was inserted, Parts and Forms were deleted or reconstituted (Forms 3‑5 deleted), and Part III was deleted. The textual marginal notes in the reprint identify where those deletions and insertions occurred (for example, "[Regulation 1 amended: Gazette 24 Aug 2007 p. 4320.]" and "[Regulation 7 inserted: Gazette 24 Aug 2007 p. 4321.]").

• Reprint. The document provided is Reprint 1 of the Warehousemen’s Liens Regulations 1952, compiled as at 2 November 2007; the compilation table identifies the reprint date and includes the amendments listed above.

Specific amendment signals within the text

• Several bracketed marginal annotations throughout the regulations indicate amendments and deletions made by the Gazette 24 Aug 2007: regulation 1 amended; regulation 2 deleted; headings deleted; regulation 3 amended; regulation 4 amended; regulation 5 amended; regulation 6 amended; regulation 7 inserted; Parts and Forms deleted or inserted as noted.

• The Notes section confirms that the current reprint is a compilation as at 2 November 2007 and lists the key gazettals and commencement dates for the original 1953 instrument, the Decimal Currency Act 1965 impact, and the Warehousemen’s Liens Amendment Regulations 2007.

What the amendment history shows, as recorded in the regulations

• The regulatory text available in the reprint incorporates the amendments up to 24 August 2007. The 2007 package appears to have been an extensive consolidation that removed obsolete parts and added the offence provision (regulation 7) while also updating citation and form content. The reprint label confirms the compilation incorporates those amendments as at 2 November 2007.

The reprint does not provide a detailed amending instrument text within its body; it records the amending instruments and the effect lines in the margins. The compilation table and marginal annotations are the only historical markers in the provided text.

The regulations as supplied contain no reported cases, judicial decisions, or citations to litigation. The instrument itself does not list any litigation history; it is a statutory regulations text, reprinted with marginal amendment notes and a compilation table. The text does not record how courts have interpreted any of the provisions, nor does it cite decisions applying the regulation-prescribed forms, timing rules or the advertising and verification mechanics.

Consequences of absence of litigation material in the instrument

• No judicial gloss in the reprint. Without reported cases in the instrument itself, the reprint does not supply any judicial interpretation of the procedural rules it prescribes, such as when a notice given under Form 2 will be held valid by a court, how strictly a court will enforce the three-month time limit in regulation 4, or how courts treat compliance with the advertising requirements in regulation 5.

• Operational uncertainty remains to be resolved in external materials. For practical or contested matters (for example, disputes over whether an advertisement complied with regulation 5(2), or whether a statutory declaration verifying a duplicate statement is sufficient evidence of compliance), the regulations do not provide guidance about enforcement practice or judicial standards. Any resolution of such uncertainty would be via case law under the Act and these regulations, but those cases are not provided in this instrument.

• Recordkeeping and evidentiary implications. Because the regulations require documentary steps (verified duplicates, particulars furnished on payment of surplus, proof of publication) but do not contain litigation precedents, parties should treat the documentary obligations as important evidence to establish compliance in any later dispute. The regulations’ lack of litigation history in the text means they do not relax evidentiary or procedural expectations; they simply prescribe the form and content of required documents.

In short, the provided regulations include no litigation history. Any analysis of judicial interpretation or contested enforcement would require consulting external jurisprudence and sources not supplied within the reprint.

This set of regulations is short and procedural, but several practical pitfalls arise from the text. The following items are points of operational risk or traps for the unwary that are directly grounded in the regulations.

• Strict three-month window for notice of lien (regulation 4). The warehouseman must give the notice of lien within three months after the date of deposit of the goods. Failure to give the notice within that period is a contravention of the regulations and therefore an offence (regulation 7). The regulation does not define whether the counting of days permits inclusion of the deposit date or how to treat partial months; the flat requirement "within 3 months after the date of the deposit" must be interpreted and applied precisely to avoid missing the deadline.

• Advertisement technicalities (regulation 5). If the warehouseman is obliged to resort to advertisement service because the intended addressee is unknown or no address is known, the advertisement must include a full copy of the notice and be published at least twice with an interval of at least seven days between the advertisements (regulation 5(2)). The regulations require publication in a newspaper circulating in the locality of the warehouseman’s premises and, where that newspaper is not a daily, in a daily newspaper circulating in the City of Perth as well. Mistakes here , failing to include the full text in the advertisement, incorrect interval between issues, publication in the wrong paper, or failing to include a Perth daily where required , can make the advertisement invalid and thereby fail to effect service. The regulations make the date of service the day on which the last advertisement appears (regulation 5(3)); that deemed date is critical for timing any further steps.

• Statutory declaration verification (regulation 6(1)). Duplicate copies of the statement of account must be verified by statutory declaration executed by the warehouseman or a competent person on the warehouseman’s behalf. The requirement ties the statement of account to the formal statutory-declaration regime. Errors in who signs the declaration or defects in the statutory declaration may render the verification ineffective for regulatory compliance.

• Detailed particulars required when paying surplus (regulation 6(2)). At the time of paying the surplus into a Magistrates Court or to the Treasurer, the warehouseman must provide a written set of particulars including deposit date, the names and addresses of the depositor, owner and all claimants and grantees under bills of sale of which the warehouseman has notice, particulars of all claims known to the warehouseman, particulars and results of searches under the Bills of Sale Act 1899, and other transaction information known to the warehouseman (regulation 6(2)(a)-(e)). These requirements create evidentiary burdens: the warehouseman must have conducted and retained searches, and must maintain accurate records of known claims, deposit dates and addresses. Incomplete particulars could be treated as contraventions.

• Forms are prescriptive (Schedule 1). The Form 1 template requires the claimant to authorise the warehouseman to serve notices at a nominated address; omission of that detail or incorrect completion may affect the practical ability to effect service. Form 2 includes a tabular schedule requiring multiple specific entries; incomplete or inaccurate entries could run afoul of the regulation’s requirement that the notice be in accordance with the form.

• Low penalty does not mean no risk (regulation 7). The penalty is only $20, but the regulations treat any contravention as an offence. The small monetary penalty may suggest low practical exposure, but failure to comply with the notice, publication or verification rules can have consequences beyond the $20 fine, including the undermining of the warehouseman’s procedural compliance in any subsequent contest about title or the validity of a sale.

• No provision for electronic or other modes of publication. Regulation 5 prescribes newspapers and does not provide for electronic publication, email service, or other modern modes of notice. Reliance on electronic methods not provided for in the regulation risks non-compliance if the warehouseman treats them as substitutes without ensuring adherence to the newspaper publication requirements.

• Cross-reference to external Acts without procedural detail. The regulations require reporting of searches under the Bills of Sale Act 1899 but do not explain how those searches are to be conducted or what constitutes sufficient search evidence. Warehousemen must therefore be aware of the separate statutory regime and maintain appropriate records of searches.

• Ambiguities left to external law. The regulations supply forms and timings but do not define the substantive conditions of lien, what justifies sale, or how disputes over competing claims are resolved. Those substantive matters remain governed by the Act and other law, which means compliance with the regulations is necessary but not sufficient for resolving underlying disputes.

Recognising these practical "gotchas" is important: the regulations focus on precision in timing, publication and documentary verification; failure in any of these discrete areas can have disproportionate procedural consequences when rights and competing claims are contested.

The regulations set out a clear, checklist-style set of steps that warehousemen and claimants must follow. Below is a practical, source-grounded compliance checklist for each relevant actor.

For warehousemen

1. Record deposit date carefully. For every package or consignment taken into storage, record the date of deposit accurately because the three-month notice window (regulation 4) is measured from the date of deposit.

2. Use prescribed Notice of Lien form. If giving notice of lien, use Schedule 1 Form 2 and ensure the notice is given within three months after the date of deposit (regulation 4). Complete the Form 2 schedule entries: description of goods, location of warehouse, date of deposit and name of depositor.

3. Maintain address information. Before resorting to advertisement, make reasonable enquiries to identify the person to be notified and their address; only where the person is unknown or no address is known may notice be given by advertisement (regulation 5(1)).

4. If using advertisement, comply exactly with publication rules. Prepare an advertisement that contains a full copy of the notice. Arrange publication at least twice with an interval between appearances of at least seven days. Publish in a newspaper circulating in the locality of the warehouseman’s premises, and if that newspaper is not a daily, also publish in a daily newspaper circulating in the City of Perth (regulation 5(2)). Retain original affidavits or publisher statements proving dates of publication, and note that service is deemed to occur on the day of the last advertisement (regulation 5(3)).

5. Prepare and verify duplicate statements of account. When the Act requires duplicate copies of the statement of account to be furnished (see the reference to section 10(4) in regulation 6(1)), ensure both duplicates are verified by a statutory declaration executed by the warehouseman or by a competent person on the warehouseman’s behalf. Keep the statutory declaration on file.

6. When paying any surplus into the Magistrates Court or Treasurer, supply full written particulars. At the time of paying surplus, supply the particulars listed in regulation 6(2)(a)-(e): date of deposit; names and addresses of depositor, owner and every claimant and any grantee under bills of sale of which the warehouseman has notice; particulars of all claims known to the warehouseman; particulars and results of searches made under the Bills of Sale Act 1899; and any other information known to the warehouseman relating to the transaction. Keep copies of all particulars provided to the receiving institution.

7. Conduct and record searches under the Bills of Sale Act 1899. If you have notice of bills of sale, make searches under that Act as appropriate and retain records of the searches and their results for disclosure under regulation 6(2)(d).

8. Keep a complete compliance file. For each matter that may proceed to sale or payment of surplus, retain: notices sent and their proofs of delivery; statutory declarations verifying statements of account; publisher certificates or affidavits for advertisements; copies of particulars furnished to the Magistrates Court or Treasurer; and copies of Forms 1 and 2 as filed or received.

9. Treat the regulations as mandatory. Non-compliance is an offence under regulation 7. Although the monetary penalty is $20, follow the procedural steps diligently to avoid any adverse consequence in subsequent disputes or challenges to the validity of notice or sale.

For claimants / owners

1. Use Form 1 when claiming ownership or an interest. Give notice in accordance with Schedule 1 Form 1 (regulation 3). Include full particulars of the goods and, where claiming only an interest, specify the extent of that interest in the form.

2. Nominate an address for service. In Form 1 the claimant is asked to authorise the warehouseman to serve all notices required by the Act at a nominated address. Provide a reliable address to ensure subsequent notices reach you.

3. Keep proof of service and copies. Retain a copy of the completed Form 1 and any postal receipts or acknowledgements to evidence that the claim was lodged and the address for service was notified.

For anyone relying on advertisement service

1. Verify publication dates. Where the warehouseman gives notice by advertisement, obtain or request proof of the dates of publication and retain the newspaper clippings or publisher certificates because the deemed date of service is the date of the last advertisement (regulation 5(3)).

2. Monitor the City of Perth newspaper where required. If the local newspaper is not a daily paper, ensure publication also occurs in a daily Perth paper as the regulation requires.

General compliance points

• Statutory declarations must be properly executed. Ensure statutory declarations verifying duplicate statements of account comply with the statutory-declaration rules applicable in Western Australia (the regulations require verification by statutory declaration but do not set the declaration’s formalities).

• Use the exact templates. Use Schedule 1 Form 1 and Form 2 wording and structure to avoid technical non-compliance with the regulations’ requirement that notices be "in accordance with" those forms.

• Keep contemporaneous records of all searches, claims, notices and communications. Regulation 6(2) requires disclosure of searches made and particulars known; keeping contemporaneous records reduces the risk of incomplete reporting and supports compliance in any later review.

• Treat the regulations as the procedural minimum. Compliance with these regulations supplies the prescribed procedural steps associated with the Act; separate substantive obligations and remedies remain in the Act and other law.

Following these steps will align practice with the regulated procedures as laid out in regulations 3 through 6 and Schedule 1, and reduce the risk of contravention under regulation 7.